Why You Must Kill the Notion of a “Compliance Plan”

March 21, 2016

You might not think that you are your brother’s keeper, but in the context of a medical group in which you’re an owner, you certainly are. I’m talking in terms of liability for billing errors.

And, of course, “brother” includes all of the providers in your group, from independent contractors to employees to partners.

After all, you’ve got to be your colleagues’ keeper because your financial interests are intertwined with theirs. If and when they make a mistake in their billing, whether negligent or fraudulent, the group’s assets are on the line for repayment. Because you have an interest in those assets, it’s your ass that’s on the line, too.

Medical groups try to manage this risk by having a compliance plan. But a plan isn’t what’s needed; it’s actual compliance, which seems to be in shorter supply.

In fact, simply having a compliance plan filed away in some blue binder sitting on your shelf lures you to the mistaken belief that the plan is somehow the same thing as compliance, just like some people think that a map is an accurate depiction of reality and then get mad at reality when it doesn’t match the map.

Sure, let’s start with assessing the current state of compliance, determining a baseline so to speak. Let’s even move on to creating that compliance plan. But we still need to keep on moving, to check and audit and educate, and to plug the gaps when we find them.

Despite what’s probably your unwillingness, you are your brother’s keeper in terms of fiscal responsibility for billing errors. You won’t likely have to do the time, but you will pay have to pay the dime (or hundreds of millions of them).

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