The Office of the Inspector General (OIG) has continued its crackdown on DSO non-compliance. DSOs should be wary of continued scrutiny regarding DSO structures along with the heightened suspicion of fraud and abuse in the dental industry. Recently, Congress has expressed concerns regarding DSOs, which includes calling on HHS to exclude from Medicaid participation any corporate-owned dental clinics using “deceptive practices” that result in unnecessary or substandard care.
OIG’s Corporate Integrity Agreement (CIA) tend to follow similar structures which are on the rise. All DSO’s should be aware of CIA’s and how they can dramatically interfere with day to day operations. Compliance is no longer an option.
Below is a list of seven (7) items for DSOs to consider:
1. Establish effective compliance policies and procedures.
2. Designate a Compliance Officer and compliance committee.
3. Train and educate staff members regarding compliance.
4. Continually review the compliance program.
5. Report and respond to issues effectively and completely.
6. Monitor and correct any quality of care or medical necessity issues.
7. Ensure accurate billing and coding for services rendered.
Stuart J. Oberman, Esq.
Stuart J. Oberman is the founder and President of Oberman Law Firm. Mr. Oberman graduated from Urbana University and received his law degree from John Marshall Law School. Mr. Oberman has been practicing law for over 28 years, and before going into private practice, Mr. Oberman was in-house counsel for a Fortune 500 Company.
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