Healthcare and Regulatory Issues: What Audiologists Need to Know

Editor's Note: This is a transcript of a live recorded course. To view the full course, register here: /audiology-ceus/course/professional-issues-ethics-practice-management-marketing-business-issues-healthcare-and-regulatory-issues-what-19706

The regulatory environment in healthcare is increasingly more complex and far reaching. In the effort to manage healthcare dollars efficiently, reduce fraud and waste, and to hold healthcare providers accountable for responsible care, state and federal statutes are becoming more stringent. Audiology is not immune, and it is appropriate that all licensees be aware that these regulations are applicable to our profession and to our practices. Over the years, I am observing a higher degree of oversight, and a much greater level of responsibility assigned to licensees. If we fail or neglect to heed these regulatory requirements, we may face undesirable consequences, so it is important for us to become aware of and familiar with these laws. We are going to review some of the most common regulatory areas that apply to audiology and I'll share some of our experiences related to audits and related activities. I have includee some examples of both compliance and noncompliance, along with tips for developing programs to meet the requirements.

Our objectives for today's presentation are, first, to create an awareness of federal and state regulations that impact audiology service providers. Second is to encourage written plans and procedures that address the healthcare rules where indicated, and then finally to provide tips for implementing those plans and procedures actively into our practices through training and monitoring programs that support compliance. It is important to note that the thoughts I am going to share with you today reflect my learning and experience in these matters, and I in no way propose to be a legal expert in regulatory healthcare.

As the compliance officer for a public company for many years, I have had day-to-day interactions in each of the areas that we will talk about, and I am happy to share that with you, with the caveat that you should seek legal representation to protect your own personal and professional interests. Our goal today is to present you with a broad overview of the type of regulations that potentially impact us and then to discuss some of the risks and steps that you can take to minimize those risks.

Over the next hour we will talk about regulations that impact audiologists and provide some resources and tips for complying not only with the letter, but the intent of the rules. You have probably heard the time-honored phrase ignorance is no excuse for breaking the law. Accordingly, our major goal is to heighten your awareness that there is some culpability and an expectation that audiologists will be apprised of their roles within a broader healthcare landscape. We often speak about autonomy and how self regulation is a big part of achieving that goal. So let's take a look at some of the areas that we will be covering today. These include highlighting some of the various state and federal regulations that can potentially impact us. Federal legislation in healthcare has responded to issues around privacy, quality and efficacy, by passing certain laws that place various accountabilities on the provider. In addition to federal regulations there will also be some cases where state laws may also expand or even exceed the breadth of the federal legislation- the overall result being an increased regulatory obligation to protect the rights of patients - confidentiality, dignity and financial security. The worst-case scenario is that failure to recognize and implement procedures and processes could compromise the viability of our practices and also the safekeeping of our patients.

Far-reaching Regulations

Over the years, the federal government has issued several laws that apply to audiology practices. These range from such topics as the Americans with Disabilities Act (ADA), the Food and Drug Administration (FDA) waiver, to more recent pieces of legislation that address security, fraud, waste and abuse, and increased Health Insurance Portability and Accountability Act (HIPAA) protections. In some severe cases there could be resulting criminal and financial penalties for failure to comply. That is obviously a drastic scenario but because we have both federal and state imposed requirements, the potential downside is harsh, so we have to put it out there.

It is worth mentioning that in the healthcare arena, responsibility and accountability for aspects of care delivery are directly linked to the individual provider. This is by way of our license numbers and also our provider numbers. Be aware that we are responsible for anything and everything where our names appear, from a chart note to a hearing aid sales invoice to a super bill or third-party claim. Any impropriety that might occur along that chain of events traces back to the provider. The scope of that vulnerability is inclusive of various state licensing rules that cover advertising, required languages, money-back guarantees as well as compliance with state and federal reimbursement programs and preventing billing fraud or waste. There is a vast area of exposure.

We are reminded that we practice under our state audiology and some cases, hearing aid dispensing laws. These are going to change from time to time, so we need to stay current with some of these obligations. Examples include some of the changes by the licensing boards in regard to educational training, whether it is course work or a web based seminar. Some states are even limiting manufacturer-based trainings, which is something that we need to be aware of. Be cognizant that there can be changes to the invoicing requirements for hearing aid dispensing from the required verbiage to the font size; there are certain requirements that have to be on that bill of sale. Many states also have defined advertising rules and requirements. If you inadvertently make a mistake, you could be subject to fines, penalties and disciplinary action from the licensing board. At HearUSA we have handled a few complaints over the years from state licensing boards, and while all of those have been settled without any disciplinary action, it takes time to address them. It is a distraction and something you are going to want to avoid if you possibly can. Watch your trainees carefully and require good documentation from them.

Also stemming from our state licenses is the requirement to report suspected pediatric and elder abuse. The keyword here is suspected, elderly or pediatric abuse or neglect. This can be in the form of obvious physical or verbal abuse to things that are much less apparent, such as neglect of shelter, food or on going medical care. We do not have to confirm the abuse; if it is suspected then we have the obligation to report it to the appropriate authorities for investigation.

Let's take a look at how the ADA regulations affect audiologists. First, if you own or manage a practice with 15 or more employees, consider ADA hiring prohibitions, which disallow discriminations against qualified job applicants and workers who are or who become disabled. The second aspect of the ADA sets forth some of the structural accessibility requirements for public entities and asserts the requirement that we have to make our services available to those who have handicaps. These would be such things as handicapped parking spaces, handicapped restrooms, and even handicapped access to your sound booth. You may need to have a ramp to provide entry into the booth. Further, one of the lesser-known responsibilities is that we are required as healthcare providers to provide deaf interpreter services at our own cost if our patients request it.

Record retention laws vary by state. Various insurance contracts may have certain stipulations for record storage, but a good general rule of thumb is to follow the Center for Medicare and Medicaid Services (CMS) guidelines. They stipulate that we need to keep our records for a minimum of 10 years for adults. For pediatric patients we have to keep records for 10 years or up to age 21, whichever is longer.

Day-to-Day Regulations

We are going to move on to some of the more robust types of regulations that are more integrated with our actual day-to-day practice as audiologists. Anti-kickback statutes are intended to prevent unnecessary and excessive billing of government health programs by prohibiting what they call "inducements" or incentives for referrals. Under the federal anti-kickback laws, we cannot offer gifts or any other types of rewards in exchange for referrals where we bill federally funded health plans. In addition to the federal regulations, there can be certain state anti-kickback regulations. Sometimes state regulations extend beyond the federal programs and actually cover state or privately funded health plans. We also need to keep in mind that the term "gifts" covers different forms. Let's take a look at some possible scenarios.

In the first example, there could be an arrangement with a medical group or nursing home to send patients to you or for you to go directly into their facility and provide audiology services. If there is an exchange of money or a large gift for that arrangement given at any time, it could place you in violation of the anti-kickback regulations. In this case, if the physician offers free space to the audiologist and the audiologist is going to provide testing whereby the physician bills a third party - that might seem like the audiology practice is going to receive free space for their hearing aid business. That could be construed as quid pro quo, so make sure you are operating within a safe harbor. If you currently have arrangements with physicians you might want to take a closer look as an exercise in caution.

Fee splitting is a cousin to anti kickback regs. Under the fee-splitting statutes, one would not be able to bill Medicare or Medicaid and then offer some portion of the reimbursement to the referrer. Obviously the rationale for anti kickback regulations is that the government is trying to prevent schemes that would drive up utilization and government expense, where the primary focus does not appear to be the well being of the patient, but rather the financial interest of the two parties that are involved.

The Stark Law protects the integrity of the healthcare dollars by prohibiting referrals where the referring entity owns all or a part of the entity to which she or he is referring. Stated more simply, Stark prohibits a physician from referring to an entity where he or she has a vested financial interest. Along with the anti kickback, Stark does have some exceptions and what we call safe harbors. There is also very limited applicability of the Stark law to audiologists, but you might want to take a closer look at that as well if this may apply to you or your practice. Both anti-kickbacks and Stark law are very complicated. The best advice that we can give is to seek professional counsel if you feel that you might be wading into that territory.

While there are not currently any criminal penalties for Stark, there are other forms of severe penalties. There is no proof of intent required in some of these circumstances. Penalties include exclusion from federal health programs, denial of payment, restitution and possibility hundreds of thousands of dollars in fines. Anti kickback, on the other hand, is a felony offense, and it carries criminal fines up to $25,000 per violation, imprisonment for up to 5 years and also exclusion from government healthcare programs.

What You Need to Know About CMS

CMS is the federal entity that administers the healthcare dollars for Medicare, Medicaid and the child health insurance programs (CHIP). This includes the Medicare Advantage portion of Medicare. CMS makes the coverage determinations. They regulate delivery of services. They determine many of the policies that govern the claims and delivery of benefits. If you are participating with Medicare, Medicaid, CHIP or any of those Medicare advantage programs that are funded through these agencies, then take some time to become familiar with the expectations and prohibitions.

CMS does not allow inducements for the reimbursements of funds under any of their programs, very similar to what we just talked about with the anti kickback statutes. An example again would be to offer a small gift to anybody that comes into your office for a test or a hearing aid and you then bill one of those programs for services. That could be viewed as trying to incentivize or drive up business at the government's expense. Billing federal programs improperly is taken very seriously by the state and federal authorities. Medicare fraud exceeds $60 billion a year, and Medicaid another $40 billion - in total, about $100 billion in wasted federal and state funds annually. It is a very real threat to our country's financial security.

Fraud, Waste and Abuse

Accordingly, there has been a massive effort to detect fraud and to deter providers from succumbing to that temptation. The False Claims Act as well as fraud, waste and abuse statutes are part of this effort. These have been implemented to identify practices that are operating outside of accepted guidelines. Note that there are also whistle blower protections that cover employees that report suspected violations. Moreover, there are financial incentives to report reimbursement issues. Similar to anti kickbacks, there are criminal and financial penalties arising from these violations, as well as sanctions and possible licensure actions that could come out of a CMS-initiated investigation.

So how does CMS define waste, fraud and abuse? There are three standards that we need to look at. First, is it reasonable and necessary? Second, does it conform to professionally recognized standards? Third, is it provided at a fair price? If it involves behavior that would be considered improper compared to the behavior of a "more prudent person" it could be deemed to be wasteful, fraudulent or abusive. So let's take a look at some examples of what could fall into the fraud, waste and abuse categories.

Such scenarios include billing for services that were not rendered at all, services that are already reimbursed by another payer, duplicate billings and inconsistent fee schedule for Medicare versus private pay. In the case of audiologists, one thing that is a big issue, in my experience, is that the properly dated physician script. In the eyes of CMS, medical necessity is only established via a physician's script. Be cautious with pre-printed scripts for your office. A common marketing practice is to print up scripts that have the office name on them with the types of testing that you would like to have done or have checkboxes. CMS might view that as soliciting a referral, and they want to see the scripting done in the physician's hand writing or electronically, on the physician's letterhead. The scripts need to be dated prior to the date of service for both the claim form and test results.

Be aware that the provider of service that is in the chart needs to be the same one on the claim. That means that all the clinical documentation in that file including tests must subsequently match to the claim form. That is one of the things that an auditor will look at.

There is no legal precedent at this time for allowing any other type of provider to bill for audiology procedures under an audiologist's name or NPI. Audiologist assistants may not bill audiology procedures to Medicare. The only exception to that rule is for CFYs or audiology Au.D. externs. In this case, when the trainee can do the procedures, the supervisor has to be physically present 100% of the time in order for those services to be billed under the supervising audiologist's NPI number. Keep that in mind, because ultimately it is your responsibility to make sure that any claims that go out have your approval and that they would stand up against a chart review or audit. Pay close attention to ICD9 and soon to be ICD10 coding practices. These need to be supported by the content of the chart. There is no precedent for billing audiology services provided by a hearing aid dispensing or colleague, either.

Be careful about routinely waiving deductibles or co pays. We are to do that only in extenuating circumstances, and we should document details in the chart. Routinely waiving co pays could be viewed as an inducement to drive utilization.

In the event of governmental site inspection you should not conceal, destroy or alter any of your documentation. Do not make misleading statements to their inquiries or fail to provide accurate information of records. Those things could add to the damages and could be very detrimental to the outcome of the audit.

I came across this case on the Internet recently. An audiologist lost her career after accruing tens of thousands of dollars in legal fees and fines all for the amount of $12,000 in fraudulent billing. This happened in Missouri, which is one of the states that is cracking down on billing fraud. The audiologist faces jail time for her conviction in Medicaid fraud. I have known audiologists in my professional career that have spent decades as a service provider, only to become a victim of an audit and see their entire careers ruined or in jeopardy. They have faced life-altering legal actions, attorneys' bills plus loss of license and income from the results of audits. I know of a dozen audiologists where this has happened in a private-practice setting. It does happen.

To control waste and unnecessary spending, the government has set up strike forces across the country. Their goal is to recover the $100 billion in annual waste. It has been stated that recovering these funds is a primary source of repayment for the Obama health reform that is taking place over the next few years. A recent headline in USA Today (2011) reported that collections from fraudulent billings in 2010 approached $2 billion, which was far more than the $573 million that had been collected back in 2004. By investing in strike forces and audit processes, they put an extrar $200K into the resources, and they were able to generate another almost $1.5 billion in returns. Clearly that is something that the government sees as a very high return on their investment, so we can expect to see continued activity in that work stream.

The states of California, Florida and Texas have been identified as areas where there is an unusual amount of fraudulent billing taking place. The Office of the Inspector General (OIG) is charged with the auditing and protecting the integrity of the healthcare systems. The OIG is very much involved with CMS and watch-dogging the entire operation. They offer opinions on everything that touches those programs, what is covered, how it is paid, who participates and how they participate. They maintain a list of those that, through audit processes, have been found guilty and subsequently barred or sanctioned from federal programs. They keep a centralized database of providers on their Web site, and that database is accessed by all types of organizations to find out if providers have improprieties in their backgrounds. It is a federal clearinghouse of sorts of all types of adverse provider activities. This works in tandem with the National Practitioners Database. They communicate back and forth. The OIG is only working with federal and state money, whereas the national practitioner database collects from audiologists and also private entities. HearUSA, for example, reports into the National Practitioners Databank, as do most hospitals, insurance plans, and other organizations that formally credential their providers.

Any type of formal credentialing process is going to query both the OIG and National Practitioners database. They compile provider information across the states and communicate with licensing boards and various federal and state entities to identify the providers that are doing things that are inconsistent with the defined business patterns. If you obtain a sanction or difficulty with a single entity it can create problems for you. Any employer that has a formal credentialing process is required to report to these databases, so the chances are if you take a bad stumble, it is going to follow you for some time down your career path. There is interdepartmental coordination between the OIG, the Federal Bureau of Investigation (FBI), the Department of Justice (DOJ), and Health and Human Services. All of these federal agencies are working to attack this level of crime, which gives you an idea of how important this is.

So what is the take away for CMS? If you are a provider of a government funded program you are subject to the rules and requirements. Make sure you know what they are. You are subject to random audits. The more you bill, the more likely you are to get audited. You are going to have to copy the files and send all kinds of documentation. I have personally handled several Medicaid audits through HearUSA. In some states we do a significantly high volume of Medicaid work and we have had our share of audits. We have never been sanctioned or fined, but have made restitution. We have been subject to repayments because they are looking for every "i" to be dotted and every "t" to be crossed. The best advice that we can give you is that you need to be disciplined in your approach, your clinical work flow and your chart documentation.

HIPAA

Most of us got our fair share of HIPAA training back in 2003 when it was introduced. HIPAA is intended to protect consumer rights with regard to the healthcare practices, and it is here to stay. There is more good to it than bad, but it is cumbersome to try to embrace all of the HIPAA requirements. A few key points: In the endeavor to protect personal health information (PHI), HIPAA limits marketing without specific patient written consent. It gives the patient control over how their PHI is accessed. There is a policy for how information is transmitted via telephone and voice mail. Patients may cite alternative addresses where their health information is directed. PHI requires the written permission of the patient unless it is specifically related to payment, treatment or healthcare operations. Patients also have the right to their medical information, which means copies of their hearing tests and other related information. This is sometimes unfortunately used to purchase hearing aids on line, but nevertheless, the patient is entitled to his or her records.

There are certain forms related to HIPAA that we are required to have available for the patient, like the notice of privacy practices, consent forms and the authorization for release. We also need business associate agreements for entities that would have access to any of the business or PHI. If you are in a clinical practice setting, you need to have an efficient shredder that will destroy papers and documents to the point where they cannot be put back together. That is actually part of the Health Information Technology for Economic and Clinical Health Act (HITEC) and the American Recovery & Reinvestment Act (ARRA) in 2009 where they defined how you have to destroy PHI.

We expect there will be continued modifications and provisions as the government moves forward in trying to protect the security of PHI. The HITEC and ARRA rules just increased levels for security and destruction. That means if you are transporting electronic information through the Internet or storing it, you have to have it encrypted. The HIPAA, ARRA and HITEC regulations have put some teeth into the regulations, specifically by way of the required breach notifications. In the event that a person in your office has his or her PHI breached or potentially breached, there is a requirement to notify those individuals of the circumstances within 60 days. For example, if someone breaks into an office and steals some charts, assuming we know which charts those were, we have to contact the patients whose charts were stolen, let them know what happened, when it happened, when we found out about it, and give them some guidance about what to do. If these breaches are more expansive or involve more than 10 people, then we have to step out into what we call public breach mode, and we have to start publicizing it in broadcast media. If there are 500 or more individuals affected, we have to go to the radio and TV outlets. Any breach has to be reported to the state Health and Human Services department.

You must keep a log of breach occurrences. If you have just a few breaches a year, you could submit them on an annual basis, but if it is a significant breach then it has to be reported to HHS at the time of the occurrence. Here is something to think about. What happens if we do have a breach and lose control of that PHI? Forty percent of our patients will no longer do business with us if we have to have a public breach, 20% will consider leaving and 5% are going to hire an attorney! Federal and state fines can easily reach into the tens of thousands of dollars. Please do brush up on your HIPAA provisions if you have not taken a close look at them lately.

The HIPAA security rule has to do with the electronic security of data and making sure that we have significant protections or safeguards for both electronic data, which in the form of passwords and encryption, but also for the hard copies of documentation. It also requires physical safeguards such as having all of our files locked. We have to have rules in place for changing locks and changing passwords, especially when there is a change in personnel or a break-in. We have to have firewalls set up to discourage hackers from stealing information. All of this is part of the security rule, which is another step in securing large segments of data.

Laptops, cell phones, and personal electronic devices should all be password protected. Your cell phone is usually linked to your e mail. If you do not have that password protected, you should. Within your organization you should have cyber security policies and procedures, and trainings for your staff to make sure everybody is aware of what could happen. Furthermore, the recent HIPAA provisions state that modern copiers are actually computers, and they save data. Anything printed, scanned or copied is stored on that device. If you are going to discard it or trade it in, there are specific steps that you have to follow to dispose of the copier and protect the information.

Identity Theft

Along the lines of breaches, I should make a quick mention of identity theft. Audiology healthcare providers were originally going to be covered by the Red Flags Rule, which required a formal identity theft prevention program, but Congress exempted us from that. However, it is still something important to consider. There are 10 million people each year that are victims of identity theft, and it costs about $54 billion annually. It is the main vehicle for illegal immigrants and terrorists. We see it in healthcare when someone allows a sick friend or family member to use their health insurance, or in some instances it involves a stolen medical ID or health member ID card. We need to take some steps to make sure the persons we are dealing with are, in fact, who they say they are.

To minimize the risk of identity theft in your practice, take some steps to confirm identity at patient check in. Look for a government-issued photo ID and be vigilant in monitoring it. One of the most common ways to detect medical ID theft is through a questionable explanation of benefits (EOB). A patient or insurance company might call you and say, "I have this EOB and I did not have this procedure done." At that point it would be in your best interest, as well as the patient's, to look into the issue. See if you can help to figure out what happened and be a part of the solution if possible.

EHR and EMR

Electronic health records (EHR) and electronic medical records (EMR) are also an offshoot of the HIPAA regulations. This is an intention to reduce medical errors and costs by improving the accuracy and clarity of medical records, such as reducing duplication of testing, reducing delays in treatment and making physicians and patients better informed. The goal is to have a centralized health record that stores patient information, supported by localized electronic medical records that are at the point-of-service. You can see where a comprehensive health record could have value for the patient's well being in terms of what medications were prescribed and what treatments have done in the past, and it improves efficiency. You can see also where it might cut down on some duplication of cost as well. One thing that is important to note is that audiologists are not included as mandatory providers that have to comply with EHR requirements. If you are involved with hospitals or physicians, however, I am sure you are well aware of EHR and EMR.

The take away on HIPAA regulations is that there are federal and state penalties and fines, felonies with possible imprisonment, and civil lawsuits associated with HIPAA violations, so it is worth spending time developing a solid process to comply with HIPAA guidelines, and more importantly - training your staff.

The Federal Trade Commission

If you do direct consumer marketing in your practice be advised of the Federal Trade Commission (FTC) rules on telemarketing and commercial e mail. Legislation gave the FTC and state attorney generals law enforcement tools to combat telemarketing fraud. It also gave consumers added privacy protections and defenses against unscrupulous telemarketers. The rules are intended to help consumers tell the difference between fraudulent and legitimate telemarketing. Most of us know about the "Do Not Call" registry, which came out of the ruling. It prohibits telemarketing calls to numbers on the registry, with some exceptions, and there are some related rules that cover transmitting the caller ID number, abandoning calls and in speaking to consumers in a nonprofessional way. It is the FTC's responsibility to monitor this and also to monitor the business practices of hearing aid dispensers. They can take action against companies that mislead or deceive consumers. FTC regulations also require companies that offer warranties to fully disclose all of those terms and conditions.

The CAN-SPAM Act of 2003 regulates commercial e mail on a nationwide basis. It requires that companies properly represent the nature of the message in the subject line of the e mail. They will not allow that the source code or transmission of the e mail be tampered with. Furthermore, you cannot obtain e mail addresses in an unlawful manner. Patient information, including e mail addresses, cannot be given to someone else without the patient's expressed written permission to do that. Practices that are sending out commercial dispersion via e-mail would need to have a physical e mail address; it cannot be anonymous, and there has to be an opt-out link or mechanism in commercial e mail as regulated by the FTC.

Occupational Safety and Health Administration

OSHA has specific guidelines that audiologists are required to follow. We must have in our practices an infection control program that follows OSHA guidelines. This means that we have to have written procedures that address what our responsibilities are from a legal and ethical perspective. In this document, we need a definition of terms, to identify how the germs are transmitted from person to person, spell out the OSHA requirements and define procedure specific protocols for limiting the spread of disease in our environment. As part of this, we are required make the Hepatitis B vaccination shots available to our employees. We need to offer infection control training to current employees at least annually and to new hires within 90 days of initial employment. Documentation of training is necessary to show that you are in compliance with OSHA regulations. If you do not have an infection control program in your practice, this should be a priority.

Summary

Today we see an increased regulatory environment and audiologists are well advised to be aware of the sensitivities, statutes, risks and responsibilities. As we have worked to gain healthcare stature and the privileges of billing third parties, we have taken on the accountabilities therein. So we need a good understanding of how these regulations affect us professionally, and we need to take the proper steps to reasonably comply with the intent of the law.

We have quickly reviewed several regulatory areas. Our advice is to seek legal counsel for any specific questions that you might have. There are additional resources available from the American Academy of Audiology and ASHA, which can provide further clarification in the areas we discussed today.

To recap, consider the golden rule when it comes to how you treat patients and their PHI. Treat patients and their information with the same courtesy and respect you would want from your physician' or provider' offices. We have a responsibility to guard the wellbeing of our patients accordingly. Keep protected health information under your control with both physical and electronic safeguards. Change locks and passwords, look at your work flow and enforce confidentiality. Create a culture of sensitivity within your practice environment. Train your team to know the federal billing guidelines and expectations, and to comply with the requirements. Train them to be sensitive to the dangers of losing control of PHI or stepping outside the legal boundaries that we have talked about today.

Just as with any other business, there are risks in audiology. Our goal is to minimize risks as best we can. We still have a profession to practice and we cannot afford to devote the majority of our time to these issues. I have been directly involved in implementing processes, procedures, trainings and in building the the cultural approach to regulatory issues at HearUSA. It takes diligence, frequent reminders and a spirit of holding each other accountable. .

What we want to do is play it safe. The danger of triggering one violation is that we are likely to trigger multiple violations. Let's carefully review third party agreement and align those procedures within the overall business flow. Strive to have a very clean work flow and high quality documentation and recordkeeping so that if you are audited you can demonstrate intent or compliance with certain areas.

We also recommend an internal checks and balance system as a mini-audit process so we can catch our own mistakes and institute corrective actions. Once we get in the habit of reminding each other to be sensitive to certain pieces of information, then it becomes everybody's job to safeguard patient information and the borders of the practice against any of these improprieties. All of this will help us to stay on the right side of the law and to demonstrate that we have made reasonable attempts.

There is a Federal Resource Guide that is available on the American Academy of Audiology Web site (www.audiology.org/practice/compliance/Documents/20110303_PCC_chart_fed_reg.pdf). They have excellent resources available under Practice Management, Compliance from their homepage at audiology.org. They have listed a number of regulations, what they cover and where you can get additional information. Other resources that might be helpful to you are your state licensing boards and CMS.gov.

I hope you have a greater awareness of healthcare and governmental issues as it relates to our practice of audiology. Although this has been a very brief introductory review, I encourage you to acquire the resources we discussed and to create a proactive culture within your practice. Thank you very much for your participation in the course today.

References

Kennedy, K. (2011, October 20). Money from battling Medicaid scams triples. USA Today. Retrieved December 17, 2011, from www.usatoday.com/news/washington/story/2011-10-19/medicaid-fraud-money/50831614/1