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SVU's Medicare Compliance Manual

Medicare Compliance Programs, a collection of policies and procedures designed to identify and correct regulatory and legal issues, have been identified by the federal government as the single best step providers can take to minimize the risk of any Medicare-related criminal action or any civil fines or penalties.

SVU now offers a model compliance program that can be used as a starting point and reference in the development of your compliance program. SVU's manual has been developed by its regulatory counsel, Bill Sarraille of Arent Fox.

The Manual is published in a binder, which provides for easy additions of updates that will be made available as changes in Medicare regulations require.

SVU's model program begins with an overview of some of the risk factors for vascular laboratories and provides specific guidance for:

  • retaining records and maintaining confidentiality,
  • screening individuals and contractors as required by federal law,
  • responding to government inquiries,
  • general billing instructions,
  • drafting requisition or order forms,
  • collecting co-payments and deductibles,
  • documenting orders, and
  • responding to concerns or questions of patients, referring physicians, and employees.

Advice also is provided for:

  • professional courtesy,
  • conflicts of interest,
  • supervision requirements, and
  • IDTF requirements.