The Centers for Medicare & Medicaid Services (CMS) has developed compliance program guidelines for Medicare fee-for-service Contractors. The compliance programmes are fundamentally designed to establish a culture within an organization that promotes the prevention, detection and resolution of instances of conduct that do not conform to federal and state law, or to federal healthcare program requirements.
An effective compliance program should both articulate and demonstrate the Contractor’s commitment to ethical and legal business conduct. The governing body of the organization, including the board of directors, chief executive officer and senior management, are tasked with the responsibility to provide ethical leadership and to ensure that adequate systems are in place to facilitate ethical and legal conduct.
The development and implementation of a compliance program is voluntary. A compliance program is not a panacea guaranteed to eliminate the risk that fraud, waste, abuse or inefficiency will occur. Nevertheless, CMS believes that the establishment of an effective compliance program will protect the Medicare Trust Fund by significantly reducing the risk of unlawful or improper conduct, and will likely lead to other programmatic efficiencies.
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