Third-party biller compliance guidance emphasizes risk awareness

The voluntary compliance guidance for third-party billing companies released by the HHS Office of Inspector General (OIG) in December 1998, like the OIG's previously released guidance directed at hospitals, home health agencies, and clinical laboratories, identifies seven minimum elements for an effective corporate compliance program: written compliance policies, designation of a compliance officer, ongoing training, open lines of communication, guidelines to ensure the enforcement of compliance standards, internal monitoring and auditing of compliance activity, and procedures to respond to and correct errors. Three areas of concern for third-party billing companies are emphasized in the new guidance document: compliance risk, claims documentation, and disclosure of suspected misconduct or fraud.