Creation and implementation of a corporate compliance program (CCP): The Illinois CancerCare (ILCC) experience.

Abstract

256 Background: In 2000, Office of Inspector General (OIG) provided guidance for physician practices in the adoption of corporate compliance program (CCP). The notice provided a basic outline that would allow organizations to detect, prevent and possibly report potential fraud and abuse as it relates to federal health care payers. Insurance payers, e.g., United, Healthcare, and Humana, are also requiring organizations to institute CCP for reimbursement. As health care reform evolves there is will be a greater need for an alliance between providers and payers as each are increasingly held accountable for their actions related to ethical behavior in documentation, billing and coding, HIPAA, improper inducements, kickbacks, financial conflicts of interest, in addition to other areas. Methods: The Illinois CancerCare (ILCC) is one of the largest private oncology practice in Midwest. We implemented the components outlined by OIG by completing the following tasks: identifying and empowering a compliance officer; identifying high-risk areas; developing policies and standards for major processes that might lead to fraud, waste, or abuse; developing a training program for all physicians, NPs, and employees; creating and implementing an auditing and monitoring program; developing investigation and remediation standards; and establishing committees for oversight. Results: The entire process took 18 months to be fully functional. We have developed a plan that is completely complaint and meets all the criteria as required and our personnel have been trained. Conclusions: In future most large practices in the United States will likely be required to have a CCP. It is complicated and includes multistep processes. In the end, implementing a CCP allows organizations to show their desire to be a quality organization with internal monitors to ensure they are participating in federal health care programs using ethical standards.