Compliance
PA SSING YOUR FSCO E XA M I N ATI ON
S
ince Service Provider Licensing was introduced in December 2014, FSCO’s
Senior Compliance Officers have been performing random examinations
(audits) at clinics across the province. How can your business be sure to receive
a clean bill of compliance? We break it down by focusing on the five most
common examination results so far.
Let’s Get Acquainted: The
Education Stage
We are currently in the “education stage”
of Service Provider Licensing. What does
compliance look like? What kinds of
records, policies and procedures will a
Senior Compliance Officer check for?
What about patient confidentiality? FSCO
is using these examinations to discuss
these topics with practitioners across
the province so that expectations are
clear and your specific questions are
addressed.
This is also a chance for you to
educate FSCO. From your perspective,
what should they understand about
the insurers? Senior Compliance
Officers have been hearing from
practitioners about late payments by
insurers (and not paying interest on
those late payments) and insurer misuse
of Section 46.3 statutory declaration
requests. Practitioner feedback recently
Officers understand what is happening
from the practitioner perspective.
If your clinic is examined this year and
is found not to be compliant, the Senior
Compliance Officer will spend time
encouraging industry-based solutions
2
Lacking complete written policies
and procedures on billing practices.
3
OCF Forms lacking the health
professional’s signature or the
patient’s signature.
and best practices. FSCO’s main goal
at this point is to verify that you have
business policies and procedures in place
4
Excellent compliance: No findings to
report.
which address compliance with your
Service Provider Licence. If not, they’ll
leave you with a list of recommended
changes.
5
Out-of-date information in the
Licensing Portal, especially contact
information.
FSCO regulates many industries and
has followed this process of educating
new licensees in the mortgage industry,
the pension industry and others. If
Let’s Get Compliant
Verifying Patient Identity
FSCO continues to find a lack of
Every health professional associated
compliance after this education phase
with your Service Provider License
from businesses that do understand the
who provides goods or services to
rules, then they will begin to escalate to
a patient must be able to verify that
enforcement.
this person was involved in a specific
motor vehicle accident. This should be
Top Five Results of FSCO
Examinations
done before treating the patient, or as
on.ca/en/auto/autobulletins/2015a/
FSCO has shared the top five results of
include:
pages/a-03-15.aspx) reminding them
the first 221 examinations performed as
of their compliance requirements for
of March 2015, in order of frequency:
helped to trigger a FSCO bulletin to
auto insurers (http://www.fsco.gov.
prompt payment. FSCO regulates both
service providers and auto insurers, and
feedback about your experiences with
insurers helps Senior Compliance
18
SPRING 2015
1 verifying patient identity (the top
Not
result by far).
soon as possible after treatment. Some
verification methods you may consider
∞∞ Requesting to view photo identification (e.g., driver’s licence), and
∞∞ Reviewing the accident/police report
or hospital records.