CodeMap Compliance Briefing: 6/18/04
This week we will continue our discussion of the Draft Supplemental Compliance Program Guidance for Hospitals published by the OIG on June 8, 2004. As stated last week, the draft guidance is not intended to replace existing compliance program guidance for hospitals, but rather supplement the earlier guidance with more in-depth compliance program recommendations and an expanded discussion of particular risk areas.
Also, it is important to remember that all providers, not just hospitals, should pay attention to this new guidance. The OIG has repeatedly advised providers that they should not wait for guidance specific to their type of organization, but rather develop their own compliance programs based on relevant provisions of guidance for other types of providers. Radiologists and pathologists should take note. Just beacuse the OIG has yet to develop compliance program guidance specific to your organizations, does not mean you are off the hook, so to speak, concerning compliance programs and their related functions.
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