Model compliance plan due soon from HHS; consortium readies itself

Document can help you fend off fraud claims

By the time this issue of Hospital Peer Review reaches your desk, the Office of the Inspector General (OIG) in the Department of Health and Human Services in Washington, DC, should have posted its model compliance plan for hospitals at its World Wide Web site (http:// While most expect the plan to be modeled on the document the OIG created for laboratories, there are sure to be some provisions specific to hospitals. (See the October issue of Hospital Peer Review for several articles on compliance.)

As this issue goes to press, federal officials are putting finishing touches on the model compliance plan for hospitals, says OIG spokes woman Judy Holtz. In anticipation of this guidance document from the feds, a consortium of leaders from 10 of the largest integrated delivery systems and multispecialty group practices has stepped forward and formulated a private effort to respond to the increasing government attention on fraud and abuse in Medicare.

Representatives from the Mayo Clinic in Rochester, MN; HealthSystem Minnesota in St. Louis Park, MN; Scott & White Clinic in Temple, TX; Virginia Mason Medical Center in Seattle; The Permanente Medical Group in Oakland, CA; Henry Ford Medical Group in Detroit; Fallon Clinic in Worcester, MA; Catholic Health Initiatives in Denver; Alton Ochsner Medical Foundation in New Orleans; and Catholic Health Care West Medical Foundation in San Francisco formed a National Compliance Consortium. The Washington, DC-based consortium has formulated six areas of advice for health care organizations regarding compliance:

• Develop and institute a systemwide compliance plan (CP) with established standards and procedures to be followed by all employees and agents.

• Designate a high-level employee to manage the plan and oversee compliance with the organization’s approved standards and procedures.

• Commit both internal and external resources as necessary to effectively communicate the organization’s approved standards and procedures to all employees and agents through educational seminars and printed materials.

• Implement a comprehensive and confidential reporting system whereby employees and agents can report suspected improper conduct by individuals within the organization without fear of retribution.

• Develop internal monitoring and auditing systems to detect improper or unlawful conduct and appropriate disciplinary mechanisms.

• Assist other entities within the industry as they develop CPs consistent with their own mission as well as with the sentencing guidelines followed in federal courts.

• Work with the public and government to ensure mutual understanding and agreement regarding health care compliance laws, regulations, and activities.

[Editor’s note: Attorney Susan Whitaker is available for more information on the consortium and its advice: (202) 672-5453.]