School for (avoiding) scandal

The AMA has launched an online tutorial for its member physicians and their staffs to keep in compliance with fraud and abuse rules.

Editorial. Feb. 28, 2000.

Government audits. Medicare reviews. Search warrants. Subpoenas.

Those are the four images that pass through the minds of many physicians when the government announces a step-up of Medicare fraud and abuse enforcement, just as President Clinton did when he submitted his new federal budget earlier this month. That the vast majority of those doctors have done nothing intentionally wrong doesn't necessarily make those impressions go away.

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Physicians are fearful at the prospect of being caught up by an intensely complicated system of government health plan rules paired now with an increasingly aggressive enforcement stance by authorities. It is not difficult to imagine situations that might play havoc with the professional lives of the innocent as government fraud-busters search for the guilty. At the very least it is an invitation for physicians to become overly cautious when they try to get paid for what they do. In the wake of all this, patients can be put in a pinch as doctors try to cut their risk by cutting their participation with Medicare and other programs. Many physicians have said they intend to do so.

In light of all the physician concern, it is fitting that when the AMA launched its online tutorial program on fraud and abuse compliance last month, the course's first offerings covered those four items listed at the start of this editorial. Those lessons provide a quick and broad education in what to think and do when someone from the government comes knocking at your practice door.

The tutorial program of which they are a part is called the Compliance Interactive Tutorial System and is available exclusively for AMA member physicians and their staffs. Future modules in the online-only program will be added periodically to address other issues of compliance in government fraud and abuse matters. Each tutorial module includes lessons, self-quizzes and Web links or contact information for additional resources.

The CITS program places fraud and abuse prevention in a context of educating physicians about how to avoid improper billing, as opposed to creating a climate of fear. Long before CITS, the AMA suggested that physicians, in any size practice setting, adopt a compliance plan as part of good business practice. The CITS program is a valuable building block in the education component needed for such a compliance strategy. It is especially timely in light of HCFA's recent launch of the process for preparing voluntary guidelines for physician individual practice and small group compliance programs. A draft of the guidelines will probably appear in the spring.

As noted earlier, the CITS tutorial is exclusively for AMA members; after all, they paid for it. But its creation telegraphs a message that should register also with doctors who will not be able to access it: Compliance involves knowledge that can be technical and complex. Answers can't be puzzled out on the spot when a government investigator is waiving a subpoena in your office manager's face.

In this instance we're reminded of Dr. Benjamin Spock's famous book that taught America's parents how to care for their children. It starts with these words: "You know more that you think you do." As the AMA helps some no-less-rattled doctors figure out how to avoid that official knock on the practice door, perhaps some less comforting but equally true words belong at the start of its tutorial: Doctor, you know less than you think you do.