Medical Practice Management
Mar 31

Will physician practices be required to implement a compliance plan under new healthcare reform?

The section in question amends 42 U.S.C. 1395cc(j) to include a requirement that all providers and suppliers establish a compliance program.  The definition of "supplier" in 42 U.S.C. 1395x(d) includes physicians.  So far, I haven't found a provision that exempts physicians from the requirement to have a compliance program. 

This is the language at issue (Section 6401 of H.R. 3590):

(7) COMPLIANCE PROGRAMS.—

‘‘(A) IN GENERAL.—On or after the date of implementation determined by the Secretary under subparagraph (C), a provider of medical or other items or services or supplier within a particular industry sector or category shall, as a condition of enrollment in the program under this title, title XIX, or title XXI, establish a compliance program that contains the core elements established under subparagraph (B) with respect to that provider or supplier and
industry or category.

‘‘(B) ESTABLISHMENT OF CORE ELEMENTS.—The Secretary, in consultation with the Inspector General of the Department of Health and Human Services, shall establish core elements for a compliance program under subparagraph (A) for providers or suppliers within a particular industry or category.

‘‘(C) TIMELINE FOR IMPLEMENTATION.—The Secretary shall determine the timeline for the establishment of the core elements under subparagraph (B) and the date of the implementation of subparagraph (A) for providers or suppliers within a particular industry or category. The Secretary shall, in determining such date of implementation, consider the extent to which the adoption of compliance programs by a provider of medical or other items or services or supplier is widespread in a particular industry sector or with respect to a particular provider or supplier category.’’.

If you hear of anything let me know. Obviously stay tuned for further details.

About Reed Tinsley, CPA

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