Developing and Updating a ''Compliant'' Lab Compliance Plan (Medicare and Medicaid Focus)

Why Should You Attend:

With the enactment of PPACA in 2010, Compliance Plans are now mandatory for all providers who bill Medicare and Medicaid for their services. Each provider covered by PPACA, must develop and implement a Compliance Program “appropriate to its characteristics”. This legislation is being enforced by the Office of Inspector General, OIG, within Health and Human Services, or HHS, Department.

This session provides an easy to follow outline for developing and updating the required HHS Laboratory Compliance Plan. Since the OIG has a zero tolerance policy for fraud and abuse, it is imperative that Laboratory Management and Administrators responsible for the Laboratory are knowledgeable about, and actively working toward maintaining compliance with the elements of the OIG Lab Model.

We will discuss required documents, staff training, audits, and helpful websites, to provide examples that each attendee may use to fulfill and update their Compliance Plan. In addition, we will identify future changes to regulations, and provide suggestions on ways to stay in compliance.

Areas Covered in the Seminar:

• PPACA Legislation of 2010.
• Required Elements of the Compliance Plan.
• Definition of Medical Necessity.
• Disciplinary and corrective action related to breach of the Compliance Plan.
• Examples of documents, reviews and audits to maintain compliance.
• Ongoing review of changes to regulations.
• Investigate ways to update the Compliance Plan.
• Websites available for information.

Who Will Benefit:

• Laboratory Managers and Directors
• Pathologists
• Administrators overseeing Clinical Laboratories
• Compliance Officers

Instructor Profile:

Pam Tayon Colker, has a degree in Biology from Hollins University, Virginia, and her Medical Technology Internship from Mt. Sinai Medical Center, Miami Beach. She has two MBA's; Human Resources Management, from DePaul University, Chicago, and Information Systems Management, from the University of Tampa.

Pam is a licensed ASCP Medical Technologist and Florida Clinical Laboratory Supervisor with 20 years of managerial experience, with the majority in laboratory consulting, with Health Care Development Services and SCC, SoftComputer. She has also been a Laboratory Director at hospitals in the Chicagoland and Tampa Bay areas.

Pam is the Principal with TC Consult, Inc., a physician office laboratory consulting firm, and Medical Technologist at OneBlood, Inc., formerly Florida Blood Services. She has given breakout sessions at several Clinical Laboratory Management Association Meetings and written articles for CLMA, Advance for Administrators and the American Association of Family Practice.

Topic Background:

With the enactment of PPACA in 2010, Compliance Plans are now mandatory for all providers who bill Medicare and Medicaid for their services. The OIG is taking a “Zero Tolerance” stand on fraud and abuse related to Medicare and Medicaid. In 1998 a voluntary Model Compliance Plan for Clinical Laboratories was published in the Federal Register. This plan includes requirements for physician ordering laboratory tests, as well as those for the clinical lab.

Medicare and Medicaid will only pay for lab tests that are “covered, reasonable, and necessary”. It is the responsibility of both the physician and the laboratory to comply with these guidelines. It is the physician’s obligation to provide certain diagnostic information for lab tests, and write standing orders that are ‘reasonable and necessary”. In turn, the laboratory should not charge physicians less than fair market value for their non-federal testing as an incentive to receive their Medicare and Medicaid business.

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