Where small practices carry real risk
Physician practice compliance is mostly about a handful of recurring areas rather than every rule on the books. Coding and documentation sit near the top, because claims for services the record does not support are a frequent basis for payer recoupments. Financial relationships with hospitals, labs, imaging centers, or other referral sources raise questions under the Stark law, the Anti-Kickback Statute, and New York's own limits on fee-splitting. In-office testing and other ancillary services often bring separate certification and referral rules into play. Prescribing controlled substances adds DEA obligations and New York's prescription monitoring requirements.
A compliance program sized for the practice
Federal guidance accepts that a small office cannot run a hospital-sized compliance department, but it still expects someone to own the role. Written policies, periodic coding reviews, and training that staff actually attend form the backbone, and the program has to respond when a problem is found. Practices that bill New York Medicaid above certain levels have specific compliance program obligations. Track licenses, certifications, and malpractice coverage for every clinician, and check staff against federal and state exclusion lists before hiring and periodically afterward. Keep business associate agreements in place with billing companies, IT vendors, and other contractors who handle patient data.
Starting a practice review
We begin with how the practice bills, what services it offers, and which relationships it has with other providers and vendors. Then we look for the arrangements that most often draw scrutiny, such as medical directorships, space or equipment leases, and marketing deals. If you have received an audit letter or a complaint, that becomes the first priority. We also ask who in the practice will carry the work forward once the review is done. The result is a set of fixes and a schedule for keeping the program active after the review ends.
