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Establishing and implementing necessary structure and procedures
Medicare Compliance Officer advice and consultation
Coordination and cooperation with in-house counsel
Ongoing consultation on a retainer basis
Updating policies, procedures, and forms to meet changing regulatory requirements
Liaison and routine dealings with CMS
Medicare Compliance and Quality Improvement Committee
Performance oversight and Reporting-Legal Issues
Fraud, Waste, and Abuse Policies and Procedures and Control Programs
CMS Monitoring and Reporting Issues
State/Federal Regulatory Issues
Corrective Action Plans
When CMS determines that a Provider is not in compliance with applicable regulations, it may issue a demand that the Provider promulgate and implement a Corrective Action Plan ("CAP") to remedy perceived shortcomings in the company's compliance with the regulations. These will typically be issued on short notice, requiring immediate response with submission of a detailed CAP carefully drawn to comply with the CMS requirements. Since the penalties involved will potentially be drastic, the licensed provider must immediately respond and submit a carefully prepared CAP.
The firm stands ready to respond to a demand from CMS for a CAP as an emergency matter, to provide guidance and consultation in drafting and submitting a compliance plan. Typically, every effort should be made to submit a draft in advance of the deadline given in order to obtain guidance from CMS as to the details required.
The drafting and implementation of a CAP requires immediate responsiveness, and an intensive review of the problem areas highlighted by CMS, coordination among numerous departments within the company, cooperative efforts in identifying root causes of problems and appropriate corrective actions, drafting and submission of CAP, negotiations with regulators, and follow-through to make certain that the Plan is properly and effectively implemented.