Sample Compliance and Audit Program

________________________________Corporate Compliance and Audit Program (CCAP) is a comprehensive strategy to ensure the submission of consistently accurate claims to the Medicare program, as well as all payers, and will ensure the_________ employees and administrative personnel providing services to ____________ comply with the applicable laws relating to its participation in these programs. Fraud and abuse, either inadvertent or purposeful, will not be tolerated by _____________. Therefore, the purpose of this compliance program is to meet the government's requirements relating to the delivery and documentation of care and the submission of claims relating to that care.

In order for the final claim to be accurate, the underlying data supporting the claim needs to be accurate as well. Thus, an effective compliance program requires the education of everyone who is directly involved in the patient care process as well as many of those whose jobs are related to that process.

In order to be effective, the CCAP is designed in a manner which:

• Addresses the organization's business activities and consequent risks;
  
  
• Educates those persons whose jobs could have a material impact on the process;
  
  
• Includes auditing and reporting functions designed to measure the effectiveness of the program and to remedy problems as quickly and as efficiently as possible; and
  
  
• Contains enforcement and discipline components which ensure that employees and administrators take seriously their compliance responsibilities.

This CCAP provides for an extensive and systematic approach on the part of _____________________to understand the claim development and submission process, to make employees and administrators aware of how the Medicare laws impact the performance of their job functions and states commitment of the organization to comply with the applicable laws. Employees and administrators must be made aware of the obligation of every employee and administrator to be an active participant in__________________ effort to comply with the laws and to participate in the auditing and other activities designed to identify non-compliant behavior or activities.

_______________ will ensure that the CCAP is consistent and meets the company's goals and strategies with respect to compliance activities. The CCAP is important to the company and active participation on the part of employees and administrators is a required part of their job function.

This CCAP defines the goals of the compliance program, identifies the necessary participants in the plan, develops the administration process and prescribes the resource needs.

1. Participants -- The implementation of the CCAP requires participation of individuals involved in or thoroughly familiar with the claim development and submission process, including administrators, and billing and coding personnel. The participants will be involved in the analysis of all steps in the process in order to ensure that the claim which is ultimately submitted is accurate.
   
   
2. Resource Needs -- ____________ will provide information systems resources, and make available the time of its personnel to facilitate the audits, the development and creation of education programs, and the staffing of investigation teams.
3. Elements of _____________ CCAP
   1. Compliance Standards and Procedures
      1. Employees and administrators will be held to performance and conduct standards designed to maximize correct billing procedures and eliminate errors. Adherence to the CCAP will be an element in evaluating the performance of an individual employee or administrator.

There will be generalized codes of that apply to all employees and administrators and specific rules and procedures which apply to particular employees and administrators and relate to their specific job function.

Here is where each facility must define practices of billing and coding, reporting systems, auditing, employee screening, education and discipline.

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