Certified Medical Compliance Officer (CMCO)®

The Certified Medical Compliance Officer addresses the unique compliance concerns in non-hospital health care provider offices, including small to mid-sized outpatient medical office settings, home health, hospice, DME, PT clinics, and third-party billing companies. 

CMCOs are proficient in the development, implementation, and management of an ongoing compliance program. They have advanced compliance knowledge that few medical office professionals have obtained.

The curriculum has received great feedback and is believed to be the most comprehensive, targeted compliance certification program currently available to small and mid-sized health care provider organizations.

Compliance expertise is among the most valuable and versatile attributes in healthcare. A cookie-cutter compliance plan template downloaded from the Internet won't meet federal compliance expectations. Your compliance program extends beyond the maintenance of policies and PHI. It represents an ongoing effort to operate a medical practice or clinic in an ethical manner within the four corners of the law.

Lack of knowledge won't hold up in a federal audit. Medicare and Medicaid have expanded audit contractor programs tasked with identifying fraud, waste, and abuse. UPICs, ZPICs, RACs, and other contractors are authorized by CMS to come into your office and request the documentation that supports the claims for reimbursement that you have submitted to the Medicare program. These onsite audits can occur with little or no notice and penalties can add up quickly.

An effective compliance program can benefit a physician's practice by speeding up and optimizing the proper payment of claims, minimizing billing mistakes, and may reduce the likelihood of an audit. This includes meeting regulatory obligations and minimizing threats to the organization. The CMCO curriculum provides candidates with advanced knowledge that very few practice management professionals have attained. This specialized training guides the development, implementation, and management of a complete compliance program and serves as an ideal platform for professional growth.

The CMCO Certification training covers every aspect of compliance in an outpatient medical office or facility. The training manual is packed with reference materials and resources, and tactical skills needed to develop and maintain a custom program that complies with federal guidelines and fits your unique requirements. Equally important, if you are audited, the training provides proof that your organization has taken steps to comply with applicable billing and coding rules.

Compliance structure and enforcements

• The seven elements of the compliance plan

• Health care fraud enforcement and sentencing guidelines

• False Claims Act, Stark, and the Federal Anti-Kickback Statute

• Calculation of civil monetary penalties

• Whistleblower complaints

• Legal provisions of compliance with a review of actual case examples

• Impact of Health Care Reform on enforcement statutes and practices

• Performing a gap analysis and other means of identifying practice-specific risks Billing/coding/coverage and reimbursement

Billing/coding/coverage and reimbursement

• Coding, billing and documentation considerations

• LCDs/NCDs and their applicability to coverage decisions

• Drafting and incorporating the office compliance plan

• Mission statement, codes of conduct, and organizational goals

• The growing threat of electronic security and identity theft Compliance, risks, actions and issues

Compliance, risks, actions, and issues

• Role of the Compliance Officer in the organizational hierarchy

• UPICs, ZPICs, RACs, SMERCs, and other Medicare/Medicaid contractors

• Correct handling of an audit request

• Organizational risks, peer review actions, state licensure issues

• Employee screening, staff, and patient relations

• Employee notification of obligations and consequences for failure to comply

• Drafting enforcement and discipline provisions

• Ongoing monitoring and auditing

• Overview of law enforcement organizations Medicare exclusion and its impact on an organization

Medicare exclusion and its impact on an organization

• Permissive vs. mandatory exclusion

• Co-payments, waivers, deductibles, and write-offs

• Overpayments, federal Anti-Kickback, False Claims Act, and Stark implications

• Gratuities, kickbacks, and payments to physicians

• Types of referrals that may violate one or more federal statutes

• Business relationships between your practice/clinic and other providers

• Setting up mechanisms for employees to file anonymous complaints

• Avoiding allegations of reprisal and responding to identified deficiencies

• Voluntary repayments - advantages and disadvantages of making repayment Law enforcement investigation tools

Law enforcement investigation tools

• Subpoenas and search warrants and how to respond to compulsory process

• Employment of consultants, lawyers, and other third-party advisors

• Federal and non-federal administrative appeals of denied claims

• HIPAA/HITECH and the relationship between privacy and compliance

• Business associate pitfalls to consider

• Future risks to your organization

Five hours are allotted for the certification exam and a score of 70% or better is required to earn the CMCO certification. If a passing grade is not achieved on the first attempt, candidates may re-test for an additional fee.

The CMCO is created for non-hospital healthcare professionals. Experience working in an outpatient medical office setting is recommended. The material covered in this program represents a tremendous amount of information and real-world experience, systematically presented during each session.

Each section was carefully developed especially for professionals working in outpatient medical settings by Healthcare Compliance Attorney Robert W. Liles and longtime Compliance Officer D.K. Everitt - well-tenured healthcare compliance experts. They know the subject matter inside and out.

The curriculum is taught by Robert Liles and Paul Weidenfeld, both practicing attorneys who are intimately involved in the business of healthcare compliance and management. Their teaching style is not intimidating. Their goal is to put you at ease, so you can tackle tough situations with confidence. It includes many real-world compliance examples relevant to private practices.