Compliance is the most important aspect of a successful federal workers compensation program. Compliance ensures the highest level of quality and adherence to rules, laws, and regulations. Compliance keeps the practice in business. Compliance makes patients comfortable selecting you as their doctor. Here’s the good news: compliance is easy. Compliance is common sense.
Each office is required to fully participate in the Federal Injury Centers compliance program. This includes:
Employee QuestionnairesBilling and Documentation AuditsOngoing Documented Compliance TrainingOpen Lines of Communication Between all Staff, Managers, and DoctorsAudits and Reviews from Outside Sources
Of special compliance note are the rules listed below, but it’s critically important that all Federal Injury Centers offices fully read all of the attached compliance documents and fully participate in the Federal Injury Centers Compliance Program.
1. Money is not #1. Patient care is. When patient needs and concerns are #1, the practice will have the opportunity for maximum success. Treatment decisions should never be made based on finances.
2. Marketing Compliance is critical. We never pay for referrals. We never give or receive kickbacks in exchange for new patients. Marketing = Education. Patients have the right of initial selection of physician and we support that right. When federal employees are educated on their rights and responsibilities in OWCP, they will be more likely to choose us as their doctor, but that choice is their right exclusively.
3. All treatment is based on medical necessity for each individual patient. This means that all treatment is based on patient needs.
4. The MD/DO must evaluate all new patients and must be involved in the treatment planning of all patients. MD/DO signatures are required on all forms and narratives, even if documents are written or completed by Physicians Assistants and Nurse Practitioners.
5. Any physical therapy services provided to patients must be performed by Licensed Chiropractors or Licensed Physical Therapy staff. When Chiropractors perform PT services, all 1-on-1 services must be done directly by the licensed Chiropractor.
6. 1-on-1 means exactly that – 1 licensed therapy provider to 1 patient at-a-time.
7. All documentation must match billing exactly and all billing must exactly reflect what was done with the patient in each treatment session.
8. No doctor, therapist, office, or staff member will ever bill for services or supplies that were not provided to patients. Fraudulent billing is illegal and is not acceptable at Federal Injury Centers.
9. All licensed doctors and other healthcare practitioners will follow their state practice guidelines at all times, unless those guidelines are found to be in conflict with DOL rules. For more detailed information on state versus federal guidelines, please consult with your healthcare compliance attorney.
10. Never take patients off work who are able to perform their job duties or who can perform a level of modified duties accepted by their supervisor / agency. Patients are only taken off work when it is medically necessary to do so.
1. Appoint a Compliance Officer. This person will be the lead person responsible for ensuring the Compliance Program’s ongoing success. Be sure each employee of the practice knows who the Compliance Officer is and that it’s OK to bring compliance concerns to this person’s attention at any time.
2. Get a 3-ring binder for compliance documents. Each section of the compliance program is a section in the binder. File all ongoing compliance documents in the compliance binder. Never let this drop out. This is an ongoing process in all Federal Injury Centers offices.
3. Schedule training with each department in the practice. Every employee of the practice should be trained on the entire compliance program, read all the training documents, and answer all the training test materials.
4. Schedule quarterly audits of records and billing.
5. Schedule quarterly training sessions with all employees.
Finally: Remember that sometimes things change. Be prepared to change. Always make every effort to stay in compliance and always be prepared to learn new rules or laws that will change compliance standards.