“ I think you ’ ll see a continuing refinement of best practices for addressing the current enforcement environment ,” Grizzle explains .
“ That being said , providers should continue to focus on the basics , things like ensuring you have appropriate controls so that controlled medications can ’ t be diverted from the system . If there is a diversion , taking the appropriate steps to report it , investigate it , and implement any remedial actions that are needed . Also , continuing with education and auditing functions to ensure that any potential threat is addressed .”
There needs to be a focus on patients with chronic pain , she notes . “ Those patients need medications and treatment , and physicians need to have mechanisms in place , or tools available , to provide that treatment . Providers can best protect themselves by educating patients on alternatives to opioids that will not be as addictive , will not have some of the negative side effects , but will control their pain .”
“ Any time there is a new area of enforcement or a subject of increased scrutiny , it always provides an opportunity for a healthcare provider to review their compliance program and to make enhancements to improve it ,” she adds .
ANNA M . GRIZZLE , ATTORNEY , BASS , BERRY & SIMS , NASHVILLE , TN
With over 20 years of experience , Anna helps healthcare clients address enforcement and compliance issues and respond to legal and regulatory violations . With significant experience in defending against statistical sampling and extrapolation and claims denials in Medicare and Medicaid claims audits , Anna also has saved healthcare companies tens of millions of dollars in potential overpayment demands . She also advises healthcare companies on regulatory and compliance matters , including transactions involving mergers , acquisitions , joint ventures and dispositions .
“ There ’ s always a silver lining — the new rules allow you to apply self-critical analysis to determine how to do things better and be stronger .”
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