Living under and in compliance with a Corporate Integrity Agreement (CIA) is no easy task.
The Monday afternoon Communicating with Regulators and Enforcement: Avoiding Pitfalls session gave a glimpse into the mind of regulators and prosecutors.
Our speakers pulled together a fun, scripted case study to demonstrate how internal legal, compliance, and outside counsel can successfully work together to handle Stark-related risks and issues.
As a foundation, there are seven essential elements a compliance program should have
Auditing and monitoring programs protect organizations by identifying issues early and demonstrate a commitment to compliance program effectiveness.
Physician contracts are often overlooked or thought to be a small part of compliance's role however, with Stark law, the Anti-Kickback Statute, and the False Claims Act, the stakes are too high not to pay attention.
Once you have analyzed your physician contracts, it is likely that you will find some issues that need to be resolved.
As you'd suspect, the vast majority are settled and never see a courtroom; however, it might be resolved after quite a lengthy investigation.
This is an element of ACA and is in it's first years of publication and use.
There are seven elements of an effective compliance program.
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