Centers for Medicare & Medicaid Services (CMS) Compliance Program

An effective CMS compliance program allows an organization to demonstrate its commitment to following CMS and other legal requirements. Under the 1991 federal sentencing guidelines, an in-place corporate compliance program is your best defense against the imposition of significant legal sanctions in the event of OIG investigation.

TCS's MedSafe® Corporate Compliance Program brings many financial, operational, legal, and other benefits to healthcare providers including:

• Optimized revenue stream and enhanced "bottom line" by rectifying under-billing and underpayment situations
• Reduced claim denials
• Reduced risk of sanctions, fines, punitive damages, interest awards, and instances of program exclusion
• A program that is in compliance with OIG Guidelines

Assessment

We will perform an on-site assessment to determine the problem areas in your current compliance program or to create a new compliance program customized to your organization. The results of our assessment will be provided in a Report of Findings and a Compliance Action Plan developed just for you.

Coding Assessments

We will perform an assessment of coding and billing practices and documentation practices as a prerequisite to designing a compliance implementation, training, and monitoring program. In this assessment, we:

• Review a sample of patient records for coding accuracy and compliant documentation
• Conduct chart audits
• Review forms and procedures
• Review service and frequency data
• Review the current written policies and procedures governing documentation and coding

At the conclusion of the assessment, we will provide a Compliance Report identifying areas of non-compliance and risk plus recommended corrective actions. In addition, we will provide a mock CMS letter - using CMS's actual form and format - outlining what the results and consequences would have been if CMS had conducted the audit.

Education

We will conduct education sessions for physicians, non-physician medical providers, managers, and other billing and coding personnel. These sessions draw upon the findings of the assessment to illustrate appropriate documentation and coding. Written training materials focus on the client's individual needs and problem areas. Topics include all aspects of Corporate Compliance plus Coding and Documentation for Providers (E&M Coding).

Implementation

We will assist in all aspects of compliance program implementation. Assistance may include compliance program infrastructure, internal auditing, and ongoing monitoring.

Monitoring

At regular intervals, we will perform concurrent reviews of your organization's coding, documentation of patient visits and services, and billing practices. These reviews quickly identify compliance problems and areas where further training is recommended.