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ACP-ASIM Pressroom

OIG's New Compliance Guidance Addresses Physician Concerns, Says ACP-ASIM

Sept. 26, 2000

Washington — The U.S. Department of Health and Human Services (HHS) Office of Inspector General's (OIG) new compliance guidance for physicians incorporates many of the American College of Physicians—American Society of Internal Medicine's (ACP-ASIM) ideas for improvement, said ACP-ASIM Senior Vice President for Governmental and Public Affairs Bob Doherty in a statement released today.

HHS's Office of Inspector of General developed the compliance guidance to help physician practices make sure that submitted claims are accurate.

"The final guide is far more flexible than the original draft," said Mr. Doherty. "It is voluntary and the OIG recognizes that 'one size does not fit all' and made practical recommendations for implementing compliance principles based on physician practice size. It will remain critically important, however, that the OIG continue to be responsive to suggestions for further improvement once the guidance is 'reality tested' in actual physician's practices - something the OIG has said it is committed to."

"We are particularly pleased to see that the OIG included our recommendation that physicians be encouraged to adopt the active application of compliance principles in their practices, rather than implement rigid, costly, formal procedures," he added.

ACP-ASIM provided input to the OIG throughout the development of the guidance including arranging for the OIG to meet with practicing physicians to hear their concerns. ACP-ASIM plans to have a continuing dialog with OIG, according to Mr. Doherty, to deal with compliance guidance concerns as they arise.

The College also congratulated the OIG on:

  • emphasizing that patient care must be the highest priority;
  • eliminating reference to federal sentencing guidelines;
  • recognizing that physicians don't necessarily have to implement all seven key elements of a compliance program;
  • putting more emphasis on the benefits to physicians and patients of having a voluntary compliance program;
  • recognizing that outsourcing, for example, participating in a hospital's compliance program -- may not always be feasible;
  • taking out language that suggested that a physician's compliance officer must be sufficiently independent of the billing office, recognizing that this is not practical for small offices;
  • providing several options for physicians to designate one or more staff persons as compliance officers;
  • acknowledging that most physician offices may not have full-time coding experts ("coders") on staff; and
  • softening language on disciplinary programs for staff that fail to report potential billing problems. "The OIG has indicated that further input will be sought on the guidance so it can be considered a work in progress," said Mr. Doherty. "We will continue to actively monitor the guidance's development and give input from practicing internists on how helpful - or not - it turns out to be. We are encouraging our members to consider the voluntary guidance as one more potential resource for preventing possible billing problems and government audits."

ACP-ASIM is the nation's largest medical specialty organization and the second largest physician group. Membership encompasses more than 115,000 internal medicine physicians and medical students. Internists are the major providers of medical care to adults in America and treat more Medicare patients than any other medical specialists.


  • Jack E. Pope, ACP-ASIM Washington Office, 202-261-4556
  • David Edelson, ACP-ASIM Washington Office, 202 261-4575

Page updated: 11-03-03

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