Compliance Made Mandatory – Affordable Care Act

Although compliance programs were not historically mandatory, they have increasingly become standard practice across the health care industry. Since the Office of Inspector General issued guidance for physician practices in 2000, many practices—especially larger and more complex specialty groups—have adopted some form of compliance plan.

These programs became even more important after Section 6401 of the Patient Protection and Affordable Care Act of 2010, as amended by the Health Care and Education Reconciliation Act of 2010, directed HHS and the Office of Inspector General to require compliance programs for most health care providers and suppliers. Under the statute, those programs are intended to be effective in preventing and detecting criminal, civil, and administrative violations under Medicare, Medicaid, and other applicable laws.

For physician practices, the key takeaway is that compliance should be treated as an operational priority, not a paperwork exercise. While requirements are expected to be scaled to the size and complexity of the organization, there is no universal template that works for every practice. Effective programs must be built around the practice’s actual risk profile, supported by leadership, and updated over time as the organization and regulatory environment evolve.

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