ABSTRACT
I. Questions to Answer
Questions to Answer
Are we aware of our obligations under various federal, state, and local statutes and regulations?
Have we made sure that we are in compliance with these regulations?
Have we developed a Corporate Compliance Plan to meet the federal and state statutes and regulations (e.g., fraud and abuse)?
Data Sources and Applications
Current compliance plans
CPT coding books
Outside counsel
Issues/Problems to Explore
Are we billing at the appropriate level for E/M services?
Do we review/randomly audit our billings and closely review all denials for services as “medically unnecessary”?
Have we appointed a compliance officer and a privacy officer?
Do we have a code of ethical conduct enacted by the board of directors and signed by all employees, including physicians?
Do we have a privacy policy enacted by the board of directors and signed by all employees, including physicians?
