Any compliance plan in a physician’s office has three objectives – Prevent, Detect, and Correct. Critical to any plan are staff requirements for reporting any coding or billing compliance problems the employees detect with their doctor(s). Here is sample wording from a compliance plan that deals with this issue; make sure your plan has similar wording.
RESPONSIBILITIES OF EMPLOYEES
The effectiveness of the Compliance Program depends on each employee's cooperation and willingness to bring compliance issues to the attention of his or her manager or the Corporate Administrator. If there is any uncertainty as to whether a particular situation raises a compliance issue, the employee should err on the side of caution by reporting it.
Each employee will receive training on the Compliance Program, including explicit instructions about where to report any compliance issues, or to ask questions. The Compliance Administrator cannot answer questions unless they are asked–each employee is therefore encouraged to ask questions.
B. Knowledge and Obeyance to Policy.
Each employee must know what is expected of him or her by the Compliance Administrator and abide by those expectations and be sensitive to situations that could lead them or others to violate these expectations. The corporation will do everything possible to convey clearly each employee's responsibilities. If any employee is unclear as to his or her obligation under the Compliance Program, he or she must seek clarification from the immediate supervisor or the Compliance Administrator.
Any employee's failure to discharge obligations imposed by the Compliance Program may result in termination of employment or other disciplinary action. Claims of ignorance or good intentions will not excuse non-compliance. It is essential, therefore, for all employees to know and obey their responsibilities under this program.
C. Reporting Compliance Issues. Each employee must report all actual or suspected compliance issues. These reports may be made to the employee's immediate supervisor or directly to the Corporate Administrator. The corporation prohibits retaliation against any employee who makes a good faith report of a compliance issue.