It has long been recommended that physicians and other health care professionals establish compliance programs to avoid issues of fraud and abuse. The Patient Protection and Affordable Care Act required the Secretary of Health and Human Services to establish “core elements” of compliance programs for all Medicare and Medicaid providers, including physician groups, and to set a time line for implementation. While the time line and enforcement date for compliance programs have not yet been established, it is notable that the Office of Inspector General (OIG) recommends all providers adopt formal compliance programs now. The OIG Compliance Program Guidance for Individual and Small Group Physician Practices, published in 2000, is likely to be the template for Medicare and Medicaid physician compliance programs. Other government-funded and private payer plans may also require that practices adopt a formal compliance program.

Internal monitoring and auditing is one of the 7 components of a...

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