Introduction to Compliance
This Compliance Plan (the “Plan”) applies to OneSource Medical Diagnostics, LLC, its affiliates, Expert MRI, P.C., and any other professional medical corporations managed by OneSource Medical Diagnostics, LLC (collectively and individually, the “Company”).
The Company is committed to conducting business in accordance with all applicable laws and with the highest of ethical standards. Compliance involves strict adherence to the requirements of the law as well as incorporating sound business ethics into the Company’s practices. The Company’s employees (“Employees”) and independent contractors (“Contractors”) are expected to conduct themselves accordingly.
In general, compliance refers to a company’s ability to conduct its business within the confines of the law. In the rapidly changing healthcare industry, it is increasingly important to prevent, detect, and resolve instances of conduct that do not conform to federal and state laws and other applicable requirements. The Plan and procedures stated in the Plan provide a clear mandate for all Employees and Contractors to follow.
The Plan is based largely on guidance provided by the Federal agency charged with monitoring and investigating healthcare fraud and abuse and other types of conduct that do not conform to Federal and State laws. This agency is the Office of the Inspector General of the United States Department of Health and Human Services (the “OIG”). The OIG, in its continuing efforts to promote voluntarily developed and implemented compliance programs for the healthcare industry and, thereby, reduce healthcare fraud, has developed a series of Compliance Program Guidance regulations (collectively, the “Guidance Regulations”) for various types of companies in the healthcare industry. This Plan is based on the Guidance Regulations most closely associated with the lines of business conducted by the Companies. The Plan also provides for compliance with the “anti-kickback statute” and the “Stark law.” 42 U.S.C. §§ 1320(a)-7(b)(b) and 1395(n)(n)
The Plan is designed to keep the Company in compliance with applicable legal requirements by deterring and detecting violations of the law. The benefits to the Company and its Employees and Contractors of this formal Plan are many. These benefits include:
- The formulation of effective internal controls to assure compliance with Federal regulations, private payor policies, and internal guidelines;
- Improved medical record documentation;
- Improved collaboration, communication, and cooperation among health care providers and those processing and using health information;
- The ability to quickly and accurately react to Employees’ compliance concerns and effectively address those concerns;
- Establish an efficient communications system that delineates a clear process and structure for addressing compliance concerns quickly and effectively;
- Provides a concrete demonstration to Employees and the community at large of the Company’s strong commitment to honest and responsible corporate conduct;
- Protection and enhancement of the Company’s public image;
- The ability to obtain an accurate assessment of Employee and Contractor behavior relating to fraud and abuse;
- The ability to identify and prevent criminal or unethical conduct;
- A centralized source for distributing information on health care statutes, regulations and other program directives related to fraud and abuse and related issues;
- A system that encourages Employees to report potential problems;
- Procedures that allow the prompt, thorough investigation of possible misconduct by corporate officers, managers, Employees and Contractors, who can impact billing decisions; and
- Enhancement of the structure of Company’s operations and the consistency between separate business units.