New OIG Guidance Prompts Launch of J’non Griffin’s Weekly Compliance Report

SimiTree’s leading compliance expert J’non Griffin has launched a new weekly email report detailing important compliance guidance and updates for behavioral health providers.

The first issue of J’non Griffin’s Weekly Compliance Report was emailed to behavioral health providers on Tuesday, Jan. 23. Subsequent weekly issues will be emailed throughout 2024, said Griffin, who serves as Senior VP of Coding and Compliance.

Free to subscribers, the new report will address compliance issues ranging from newly required assessments to new types of audits providers may expect to see. 

“There’s so much happening in the area of compliance that specifically impacts behavioral healthcare that I felt it was important to get this information to providers,” said Griffin, who serves as Senior VP of Coding and Compliance. “My goal for this new Compliance Report is to increase awareness of potential compliance issues. Each week I will also offer a short punch list of considerations and recommended action to providers.”     

Griffin said the new report was prompted by major changes the behavioral healthcare field is seeing at the same time the U.S. Office of Inspector General (OIG) of the U.S. Department of Health and Human Services is increasing its scrutiny of compliance and updating its guidance.

“Just a few years ago, healthcare organizations primarily viewed compliance as making certain their billing practices didn’t run afoul of Medicare’s vigilance and they were ready for the next survey,” she said. “But the healthcare space has undergone a major and rapid transformation.”

Payment structures have evolved from fee-for-service to capitated payment arrangements through insurance plans and performance-based payment. Multiple new business models are springing up across the market, with healthcare organizations restructuring their operations and adding new service lines.

“And throughout these massive shifts, we’ve seen a new and astonishing upheaval in players, owners, partnerships, and joint ventures,” Griffin said. “Any time you add new reimbursement models, new partnerships, new services, new investors, or new governing bodies to the mix in the heavily regulated field of healthcare, you open the door to multiple new compliance and regulatory risks. As the number of managed care plans and the amount of healthcare technology explodes, the risk magnifies exponentially.”

New OIG Compliance Guidance

“We know that the OIG is keeping a close watch on all the major changes in the healthcare market and ramping up overall compliance expectations for healthcare organizations accordingly,” Griffin said.  

One major indication of changing compliance expectations occurred in November 2023, when new comprehensive compliance guidance was issued by the OIG. It’s known as the OIG’s General Compliance Program Guidance or GCPG.

Its issuance marks the first time the OIG has issued such comprehensive guidance with key updates for the recommended compliance approach for all types of healthcare providers. Previously, many providers had no definitive guidance on which to base their compliance programs, and they had to cobble together compliance programs from previous advisories, rulings, and general best practices. In some cases, guidance for a particular healthcare sector had not been updated in a quarter of a century before the OIG provided the new GCPG.  

The GCPG is extensive, referencing relevant Federal laws, compliance program infrastructure, OIG resources, and other information useful in understanding all aspects of healthcare compliance. Since its release, SimiTree’s compliance experts have been busy helping both post-acute and behavioral healthcare providers understand and apply the new guidance to their operations.

 In many cases, organizations will require new or revised policies. In some cases, operational changes may also be needed. In almost all cases, a new round of education and staff training is recommended.

“We’re ready to help both behavioral health and post-acute healthcare providers with all of it,” Griffin said.

SimiTree Can Help

A thorough compliance and risk assessment is the first step for many organizations in implementing the new GCPG. SimiTree’s compliance experts work with providers to determine where they may be at risk of HIPAA privacy and security violations, including recent HIPAA changes, and identify any weaknesses in required compliance leadership and oversight. We work with organizations to put into place all OIC-recommended elements of compliance infrastructure.

“Our experts also help organizations identify and correct areas of risk in billing practices, offering pre-bill audits that offer an organization a detailed look at where it may be incurring risk or shortchanging itself,” Griffin said. “We help organizations ensure their incentive programs do not violate regulations, shore up clinical documentation practices, and address vulnerabilities in organizational processes and procedures.”

SimiTree is ready to help organizations with all their compliance needs, from ADRs, audits and appeals to survey readiness and Independent Review Organization implementation of OIG Corporate Integrity Agreements.

Sign up for the new Compliance Report

Sign up here for J’non Griffin’s Weekly Compliance Report, delivered to your inbox each Tuesday.

“I’ll personally re-cap what’s going on in our rapidly changing field, highlighting what you need to know for success and letting you know how SimiTree can help,” Griffin said.

 “I’ll tell you about a new kind of audit behavioral health providers can expect to see, explain some of the new telehealth provisions allowed for behavioral health providers in 2024, detail some of the compliance risks involved with contracts and vendors, explain the importance of making certain governing bodies fulfill their compliance oversight obligations, address some of the biggest compliance headaches for smaller organizations, and much more.”

J’non Griffin serves as Senior Vice President for the Compliance as well as Coding divisions at SimiTree.