According to the U.S. Federal Sentencing Guidelines (chapter 8) if an organization has a reasonably effective (not perfect) compliance program in place and they are sanctioned for wrongdoing the government will to give due consideration of the efforts of the compliance program?
It’s true! According to a matrix established by the U.S. Sentencing Commission fines and penalties assessed for Fraud, Waste and Abuse can be reduced by up to half if the organization had a reasonably effective compliance program in place during the time period for which the organization is found to have committed fraud, waste or abuse. Considering recoupments range from tens of thousands to millions for individual and small group physician practices, this can seriously impact a practice that is found to have make substantial errors in documentation and/ or billing.
What’s more is because compliance programs include continuous audit processes, which serve to minimize errors, the likelihood of a provider getting busted for fraud, waste or abuse issues decrease dramatically!
Like it or not – it’s not enough that you are “good people” or that you run an “honest” practice - you have to prove it!