Implications of model compliance program for interventional pain physicians

The model compliance program for small physician practices, recently released by the Office of the Inspector General (OIG) shows a remarkable degree of flexibility reflective of the OIG's acknowledgment that small physician practices have such limited resources that they might not be in a position to implement a full compliance program. The OIG suggests a step by step approach to the implementation of a compliance program which includes auditing and monitoring, establishing practice standards and procedures, designating na compliance officer or contact, conducting training and education, responding to offenses and corrective actions, opening uses of communication, and enforcing discipline through well published guidelines. The OIG's final plan also lists a wide variety of risk areas that a small practice should address in its program, many of the identified risk areas relate to situations in which physicians interact with other types of providers-including durable medical equipment suppliers, home health agencies, clinical laboratories, hospitals, and others. Although physicians have tended to equate the term "compliance" with "billing and coding" compliance, the OIG's list of risk areas reveals a much broader range of compliance issues and concerns, with particular emphasis on financial relationships between physicians and other providers. In conclusion, Physician practices are clearly at greater risk today if they fail to do so in light of the publication of the OIG's final plan.