For example, not all physician offices have access to the Internet, and much of the government resource material that is published there is difficult to access and hard to understand. As you know, the health care regulatory environment is extraordinarily complex, and even those who specialize in these matters frequently have varying interpretations of federal laws and policies that are set forth in this material. Further, the burden placed on these solo and small group practices to seek out the information they need on their own is extraordinary. For example, the recommendation that physicians check OIG's web site annually to familiarize themselves with the interest areas identified in its work plan is unrealistic. Additionally, the document refers frequently to Medicare carriers as a key source of information, even though it is not unusual for carrier employees to give conflicting guidance and instructions, and many refuse to respond to questions in writing.
Some material is expensive and changes frequently.
The claims edits set forth in the Correct Coding Initiative, for example, are modified quarterly and must be purchased from the National Technical Information Service or another private vendor. Finally, some of the most useful and detailed information on Medicare program rules, such as internal memoranda, simply is not available to physicians. The College believes strongly that the effectiveness of a physician compliance plan depends on easily accessible and accurate information at least as much as it does on physician efforts to implement good office procedures and provide necessary staff training. Surely HCFA, the carriers, and OIG bear substantial responsibility for providing this access, and must hold themselves accountable for doing so. The guidance document makes clear on several occasions that physicians must take measures to ensure that the compliance programs they implement are truly effective.