In 2000, The Office of Inspector General released a Compliance Plan for Small Physician Practices. Although it is not mandated, the OIG "recommended" that physician practices implement a Compliance Plan.

There were seven components listed:

• Standard of conduct
• Compliance officer
• Education and Training
• Reporting problems and investigations
• Responding to problems
• Audits and monitoring compliance
• Response plan and corrective action

 Many practices implemented a compliance plan in the first part of the decade.  Some adopted an off-the-shelf program, and some wrote them from scratch.  Whichever way your practice developed their plan, it is important to review it from time to time.  Make sure that you are doing the activities that you said you would in your compliance plan. It is better to have a less ambitious plan that is followed, than a very ambitious plan that isn't implemented. 

In small practices, the Compliance Officer may also be the managing partner or the administrator of the practice.  Often, the compliance committee is also the governing group of the practice.  The function of audits may be outsourced, rather than completed internally.

All physician practices should have a Compliance Plan.