Building a compliance program. Guidelines for physician practices.

Federal investigations of physician billing practices will only grow more intense in 1998. Regular self audit, especially of CPT coding, can help practices stay out of the limelight. An established compliance program and high-ranking compliance officer are also becoming standard. Compliance programs should pay particular attention to "incident to" billing, level 5 E/M codes, time-based E/M codes, codes with both technical and professional component services, consultations, critical care codes and physician care plan oversight. Even group practices that use billing companies need to stay alert. Physicians are liable for the acts of the billing company whether they knew or should have known submitted claims were false.