Courtney Blau on the Medicare Access Clause [Podcast]

By Adam Turteltaub adam.turteltaub@corporatecompliance.org The Medicare Access Clause at first glance seems simple.  If you are a Medicare provider who has subcontracted patient services (other than equipment and supplies) worth $10,000 or more over a year then you must include in that subcontract a clause “….that allows the Comptroller General of the United States, HHS, and their duly authorized representatives access to the subcontractor’s contract, books, documents and records until the expiration of four years after the services are furnished under the contract or subcontract.” According to Courtney Blau, Administrative Director of Risk Management & Compliance at Norman Regional Health System in Oklahoma, the seemingly simple provision must be applied carefully and diligently.  If the contract does not contain the Access clause then Medicare has the right not to reimburse services provided. It’s essential that compliance teams work with the contracts team, she argues in this podcast, to ensure that all new contracts contain the clause.  In addition, compliance and contracts need to assess which contracts this applies to, beginning by auditing all the service contracts.  Then determine when amendments to the agreement are needed. Listen in to learn more about your organization’s obligations under the Medicare Access Clause.