How to survive a Medicare audit of your practice. (Tips on Developing a Compliance Plan).

VAIL, COLO. -- Having a compliance plan in place provides considerable peace of mind during a Medicare or insurance company audit of a physician practice, according to Kristine M. Maier, a health care consultant and accountant in Denver.

One of the first things auditors look for is a compliance plan. They view it as an early indication that the practice they are about to scrutinize is serious about proper coding, billing, and documentation.

"If you don't have one, I strongly suggest you either call in a consultant to help you put it together, or appoint somebody on your staff you can rely on to become a compliance officer and get this implemented," she urged at a conference on obstetrics and gynecology sponsored by the University of Colorado.

There's no mystery about what an adequate compliance plan entails. The Office of the Inspector General at the Department of Health and Human Services has spelled it out in a document available over the Internet, entitled Draft Compliance Program Guidance for Individual and Small Group Physician Practices. A compliance plan has seven key elements, according to the OIG:

* Establish compliance standards through development of a code of conduct and written policies and procedures.

* Assign compliance monitoring to a designated compliance officer. A compliance plan is nothing but a piece of paper unless there's someone responsible for ensuring it is functioning, Ms. Maier emphasized. Conduct comprehensive education and training on practice ethics, policies, and procedures for the whole staff.

* Conduct internal monitoring and self-auditing. Do a quarterly review of your charts. Pull a random sample and verify that what you and your partners have documented in the chart is what was coded on the bill and sent out the door, she said.