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Do diagnostic labs need a voluntary compliance program?

Government officials continue to investigate and prosecute allegations of health care fraud throughout the medical community. Hospitals, physicians, chiropractors, dentists and diagnostic labs are all open to investigations and allegations of wrongdoing. Leaders within these markets can take steps to proactively reduce the risk of such allegations. One example: putting together a voluntary compliance program.

What is a voluntary compliance program?

A voluntary compliance program is set in place by laboratory officials to help better ensure the organization is in line with applicable rules and regulations. A well-structured plan is put together using published guidance provided by the Office of the Inspector General (OIG). It includes information for lab workers to help better ensure they are aware of and abide by the rules and regulations. It also offers a clear pathway to reporting problems within the organization, so lab leaders can address issues before they become a bigger problem.

Why should a laboratory take the time to put together a voluntary compliance program?

Labs with these programs are less likely to become the subject of an investigation into allegations of fraud in the first place. In the event of an investigation, those that have these practices in place are more likely to receive special consideration from the government officials conducting the investigation.

What should a lab use to help develop a plan?

It is important to be familiar with the laws that impact the operations of the lab. Examples include the Social Security Act, Anti-kickback laws, False Claims Act, Stark laws, EKRA and the Health Insurance Portability and Accountability Act (HIPPA). Those who are putting together the plan should know how these laws impact areas of concern that often lead to government investigation. These include areas like billing, claims for coverage due to medical necessity, and coding.

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