companies must also take an active role in screening, as outlined in this statement from HHs-OIg: For all new employees who have discretionary authority to make decisions that may involve compliance with the law or compliance oversight, billing companies should conduct a reasonable and prudent background investigation, including a reference check, as part of every such employment application. The application should specifically require the applicant to disclose any criminal conviction, as defined by 42 u.s.C. 1320a-7(i), or exclusion action.2 FEATURE sTOrY As you are well aware, compliance plans and programs are not a “one-size-fits-all” solution. In order to be effective, compliance plans must be tailored to suit a billing company’s unique attributes, taking into account its capabilities and any company-specific risks that may exist. THe jOurNal OF THe HealTHCare BIllINg aND maNagemeNT assOCIaTION 25 as OIg’s guidance further states: Pursuant to the compliance program, billing company policies should prohibit the employment of individuals who have been recently convicted of a criminal offense related to healthcare or who are listed as debarred, excluded, or otherwise ineligible for participation in federal healthcare programs. In addition, pending the resolution of any criminal charges or proposed debarment or exclusion, the OIg recommends that such individuals should be removed from direct responsibility for, or involvement in any federal healthcare program.3 If ineligible current employees or contractors are identified in the screening process, OIg notes that third-party billing companies should take appropriate action to safeguard the integrity of medicare and other federal health benefit programs. ... With regard to current employees or independent contractors, if resolution of the matter results in conviction, debarment, or exclusion, then the billing company should remove the individual from direct responsibility for or involvement with all federal healthcare programs. Excluded persons are prohibited from furnishing administrative and management services that are payable by the federal healthcare programs. This prohibition applies even if the administrative and management services are not separately billable. For example, an excluded individual may not serve in an executive or leadership role (e.g., chief executive officer, chief financial officer, general counsel, director of health information management, director of human resources, physician practice office manager, etc.) at a provider that furnishes items or services payable by federal healthcare programs. also, an excluded individual may not provide other types of administrative and management services, such as health information technology services and support, strategic planning, billing and accounting, staff training, and human resources, unless wholly unrelated to federal healthcare programs. (emphasis added.)4 again, screening new employees who may be excluded from active roles in federal health programs must be a joint effort on behalf of providers and third-party billing companies. COMPLIANCE TIP #3: Recognize the relationship between provider compliance and biller compliance. a billing company should always determine whether a provider has an effective compliance plan in place. The reason is straightforward: providers with an effective compliance plan will likely represent less of a risk than those without a plan. Does this mean that you should not provide billing services for a provider that has yet to implement a plan? No, not at all. Nevertheless, it is important to recognize that the achievement of consistent regulatory compliance requires a joint commitment
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