Compliance by Accident…is an Accident Waiting to Happen!

Out of Sight…Out of Mind

How many of you reading this blog, right now, have a compliance plan located somewhere in your office or somewhere in the station?

Compliance by Accident…is an Accident Waiting to Happen!You know what I mean, that big binder book with a lot of paper, plenty of words that seemingly took forever back in 2000-something (or maybe even before) to put together but now has a layer of dust on top of it about 3 inches thick.

It’s that book that when someone asks you if you have a “Compliance Plan” you answer definitively with even a bit of chest pumping… “YES!”

But all the while you are proud of the fact that you have a binder somewhere with the word compliance in it or on it…you are really thinking… Do I remember what’s in it?

A Plan Without Action?

And…this is where the problem is.

A quick look at the dictionary yields this definition for the word “plan”…

A detailed proposal for doing or achieving something

Note the action words…doing and achieving.

We’ve never known of a compliance plan that periodically leaps from the shelf down onto the floor and moves fluidly about your organization magically mandating that you and your staff follow the plan.

A plan without action….well…is just a plan and will achieve nothing!

How Long Has it Been?

Answer this question, right now…not later…now.


How long has it been since I last read over my agency’s compliance plan?

If your answer contains the word years…shame on you.

If you answer contains the word months…shame on you.

Worse yet, it’s not that you’ve read the plan but have you acted on the plan? If it has been years or months since you have dusted off the plan and have put any one or all of the provisions of the plan into continuous action, then you and your agency are ripe to fail and someone will take note.

Someone with a badge maybe? Someone with authority? Someone that will definitely cause you grief.

We will be audited!

Repeat this phrase out loud so you hear yourself say it…

We will be audited!

Now repeat it one more time.

Did you hear yourself?

Scary? Give you chills? If not, it should!

There was a time in this industry when a Medicare or Medicaid audit was conducted against the guy that you read about who really colored outside the lines. You could hear the rattle of the handcuffs. Jail time was imminent.

That’s not the case anymore.

For every dollar that the Feds are spending on audit activity, they are recovering around eight dollars in return. That’s not a bad return on investment!

And…with the exception of those who set out to purposely defraud the government, the dollars are being recovered from every day “normal” EMS agencies who probably have that dusty binder labeled sitting on a shelf, unimplemented.

You go along for a long time and think you’re okay and then BAM! Out of nowhere you find out that you should have paid more attention to “The Plan.”

“Radical Compliance Terrorists”

Compliance with the billing rules and regulations (of course, others too…but this is a EMS billing blog) that tell us how to do things MUST be an everyday occurrence.

The SOG/SOP’s that you follow must include compliance measures. You must audit internally for issues. Your billing office must audit internally for issues. Of course, we recommend that you contract with a billing agency that practices compliance religiously. Your billing office must be radical compliance terrorists especially with regard to the Patient Care Reporting and the documentation, signatures, PCS documents straight on through to the coding and billing of the claim.

If that doesn’t sit well with the street staff, well then it’s time they got onboard and understand why it’s so important to their wellbeing just as much as the billing office staff.

How long has it been since you read over the plan itself to be sure that all parts of it are even relevant? Things change. The plan must change too. And…do you have a way of measuring the plan’s effectiveness?

Today’s Action Item

Today we give you an action item.


Get up from your chair. Finish reading this blog.

And…wait for it…


It’s time to make that dusty plan come to life!

Review. Measure. Implement. Act.

And…then…repeat it all tomorrow and the next day and the next day…

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