FAQ 3 BlocksCompliance Training & Education Questions

Please take a moment to read through our frequently asked questions (FAQ) on compliance training and education.  Don’t hesitate to reach out and ask questions.

Is Compliance Training Required?

Yes and No.  Yes is you want to mitigate your compliance risks and take into account the requirements under the Affordable Care Act (ACA) requiring compliance training for all healthcare providers.  CMS has not yet published “guidelines” for training, but best practice, according to the Office of Inspector General (OIG) is to utilize the OIG’s existing Compliance Program Guidances that have developed and published since 1998.  For therapy providers and practices, the Compliance Program Guidance for Individual and Small Group Physician Practices (65 Fed. Reg. 59434; October 5, 2000), is recommended as a basis for a compliance program.

Is compliance training for the entire staff, or only those that treat patients?

Compliance training is for your entire organization, and at a minimum all staff should take compliance training focused on preventing fraud, waste and abuse.  Compliance training should also include HIPAA privacy and security, OSHA and other courses that may be required.  Nancy Beckley & Associates provides annual compliance training on Fraud, Waste & Abuse, as well as specific “mini-training” courses for clinical and billing staff on documentation, coding and billing.

I took a compliance course last year, does that count for compliance training?

Compliance training should be specific to your practice and provide training on fraud, waste and abuse, as well as training for staff in high risk areas including coding and billing.  You practice should document annual compliance training, the materials that were included, and a sign in sheet, attendance record or certificate of achievement.

A Medicare Advantage Plan is requiring that our clinic listening to their online fraud & abuse training, is this required?

CMS has required that Medicare Advantage Plans (also know as Medicare Part C or Medicare managed care) provide specific training (that cannot be altered) to their First Tier, Downstream, and Related Entities (FDR).  Two specific trainings are required: Medicare Parts C and D General Compliance Training, and Combating Medicare Parts C and D Fraud, Waste, and Abuse.  If you participate in Medicare Part A or Part B, then only the compliance training is required.  The Medicare Advantage Plan may require specific attestation of your completion of these courses – review your contract as well as any correspondence regarding compliance training.

Compliance Program Questions

Is a compliance program required for a small therapy practice?

See our answer to “Is compliance training required”?  In short, a small therapy practice would be creating risk by not educating all staff on preventing fraud, waste and abuse in federal healthcare programs.

What are the required elements of a compliance program?

The seven elements of a compliance program are based upon the Federal Sentencing Guidelines, and include: 1. Implementing written policies, procedures and standards of conduct. 2. Designating a compliance officer and compliance committee. 3. Conducting effective training and education. 4. Developing effective lines of communication. 5. Conducting internal monitoring and auditing. 6. Enforcing standards through well-publicized disciplinary guidelines. 7. Responding promptly to detected offenses and undertaking corrective action.

How do I get started on a compliance program?

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Questions on Taking Courses on this Site

What if I want a compliance course customized to my practice?

Nancy Beckley & Associates has been customizing compliance courses for therapy providers for nearly 20 years.  Customized courses, specific to therapy, and your practice can be provided onsite at your location, via webinar, or alternatively through this learning management system (LMS).  We have also customized courses for various state physical therapy associations.

Do you provide documentation if we complete courses?

Following the successful completion of each course, there is a brief quiz.  An 80% passing grade is required on the quiz in order to get a certificate of completion. We have many small practices that take our online compliance training on an annual basis, and they are responsible for completing each assigned course in a specified period of time, passing the quiz, and presenting the certification of completion to their employer.

How do I register to take courses?