Friday, July 27, 2012
Document, Document, Document!
With all the recent focus on the Affordable Care Act, providers need to remember the increased resources for enforcement and the need to ensure regulatory compliance at every turn. One trap for the unwary health care provider is the failure to document your arrangements with referral sources: simply put, any arrangement that involves a reasonable, fair market value payment for a necessary service must be documented appropriately. Many times, a simple letter agreement or e-mail exchange (using electronic signatures) can create the documentation (a description of the services, term, and compensation) necessary to meet the pertinent requirements of the law. Just noting the needed elements and including them in the exchange with the physician can create the needed agreement (depending on your state’s laws). There is certainly lots to be talking about these days in terms of health care compliance, but this basic rule can go a long way to keeping you out of trouble.