CodeMap® Compliance Briefing: August 12, 2011
In the past week, several subscribers have asked questions about annual physician notices. Some of these subscribers asked if we feel it is still necessary to send out these physician communications considering the OIG and other enforcement agencies have focused little attention on these compliance tools in the past few years. Our answer is that we strongly believe providers should continue to distribute annual physician notices. Despite the lack of attention, these compliance program components remain a critical part of any effective compliance program.
In addition, the recently enacted Patient Protection and Affordable Care Act (PPACA) states the following, “a provider . . . shall as a condition of enrollment in Medicare, Medicaid, or CHIP, establish a compliance program that contains certain core elements.” Although CMS has yet to finalize any rules concerning mandatory compliance programs, we feel it is safe to assume that annual physician notices, or similar disclosures, wil....
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