Welcome!

This document was initially made available by the OIG as a courtesy to people who did not have easy access to the Federal Register. It contains the public display version of the final Compliance Program Guidance for Individual and Small Group Medical Practices. This document is not the "official" version of the notice--the official document of record was published in the Federal Register on June 12, 2000. (If you would like to view the official version, click here. Please note that you need Acrobat Reader to view this document. Click here for a free download.)

The OIG recommends that organizations develop a compliance "library" from publicly available materials. Specifically, the OIG writes in this model plan that--

Creating a resource manual from publicly available information may be a cost-effective approach for developing policies and procedures. For example, the practice can develop a "binder" that contains the practice's written policies and procedures, relevant HCFA directives and carrier bulletins, and summaries of informative OIG documents (e.g., Special Fraud Alerts, Advisory Opinions, inspection and audit reports).

Davis Wright Tremaine LLP ("DWT") has developed this resource, in an easy-to-use format, to assist Compliance Officers and other persons in implementing part of the OIG's recommendation.

In support of its positions, the OIG cites various statutes, regulations, reports or other materials. Most of the citations are in footnotes. When you come to a footnote in the text of the plan, you may put your cursor on the footnote link and click to go to that footnote. The footnotes contain additional links. Putting your cursor on the links in the footnotes and clicking will take you to the authority that the OIG cites in support of its position. Using your cursor, you should be able to maneuver easily from text to footnotes, linked documents and websites.

As an example, if the OIG cites a statute, regulation or report in support of its position, a link to that statute, regulation or report is provided. In order to view the linked documents, you will need Adobe Acrobat Reader, which may be obtained free of charge through the links at the top and bottom of the screen.

The links to the cited documents are made available for education and information purposes only. The summaries and notes should not be considered legal advice. As the OIG noted in footnote 7 of the Model Compliance Plan for Nursing Facilities: "Counsel . . . should be consulted as appropriate regarding interpretation and legal analysis of laws related to the Federal health care programs and laws related to fraud, abuse and other legal requirements." If you have questions or issues that are specific to the operations of your practice, you should consult your attorney.

The Davis Wright Tremaine Health Law Department web site contains client advisories and other materials that may be of interest to persons developing, implementing or administering compliance plans. The names and resumes of DWT attorneys who work with compliance plans and issues are also provided.

We hope you find these materials useful.

Edwin D. Rauzi, Partner
edrauzi@dwt.com

The author wishes to acknowledge the assistance of Danielle Chauncey and the support of Joan White and the Health Care Association of Hawaii in preparing these materials.