Epps & Coulson


Healthcare Companies should conduct a self-audit each year of their organizational structure and operations.  The audit should include ensuring that all organizational documents (historical and any updates) are updated and that the documents are available when needed.  As with normal non-medical companies, besides organization corporate documentation, all licenses and contracts, whether for internal operations (like employment contracts) or vendors should be available and relevant dates calendared.  All insurance policies should be reviewed for updates and policy deadlines.

Healthcare providers have more stringent reviews that should be conducted than general corporations.  They are heavily regulated by federal and state governments, including for instance in the areas of HIPAA, Medicare billing, DEA or CLIA status, state licensure regulations and scope of practice limitations.  Maintaining compliant policies, practices and procedures is essential for licensure, billing, government oversight, insurance audit, and effective policies and procedures can serve as potential defenses to claims by employees, patients, whistleblowers, governmental enforcement, insurance claims and other areas of concern.  Regular review can identify problems in order to resolve them before an emergency arises, before the healthcare provider goes through a sale or merger, or other large organizational events.

And, Medical providers have additional concerns in that Medical Director Agreements, leases, and practice operations must be reviewed for anti-kickback statutes, Corporate Practice of Medicine limitations, Self-Referral admonitions, etc.  All staff licensure and certifications must be up-to-date.  In addition, medical providers must maintain staff immunization, health screening information and status of potential exclusion from Medicare, Office of Inspector General and state Health & Human Services requirements, etc.

Medical providers should also review their billing/coding and documentation practices and procedures for appropriateness, accuracy, completeness and potential upcoding.  Historical data of use of CPT codes used by providers is essential. Then, review of random samples of each provider’s billings and documentations for those billings is prudent.  Analysis of co-pay and co-insurance collection policies and practices, as well as review of policies and procedures for credit balances should be completed annually to ensure compliance.

Providers ought to also review utilization policies of non-physician providers.  Then, training materials for each employee position should be updated and documented, as well as documentation for annual training for compliance with state and federal laws and regulations.

Last, vendor agreements for all areas, including leases, pharmacy or laboratory contracts, marketing agreements should be reviewed for anti-kickback issues, self-referral compliance, prohibitions on corporate practice of medicine, etc.

If you need help with any of this, please contact us.  Epps & Coulson, LLP regularly does compliance audits and specified reviews of policies, practices and procedures for our medical provider clients.  Feel free to contact Dawn:

Information contained in this Memo is intended for informational and educational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.  It is considered advertising under laws of some states.  Epps & Coulson, LLP encourages you to call in order to discuss these matters as they apply to you or your business.


Attorneys admitted to practice in

California, New York, Colorado, Texas and Oregon