Compliance
A program is what you can show this month, not a binder on a shelf.
Compliance work fails quietly: a policy that does not mention the services you bill, training with no date, or a monitoring sample nobody reviewed. This center collects the firm’s compliance notes and a pulse-check list. It is not a certification and not a finding about any organization.
Reviewed by Joseph Rivet, Esq. · October 1, 2026
Start here
The questions this center answers
Compliance program notes from Rivet Health Law: what a working program can show, and what a privacy or false-claims headline does not prove about your file. Reviewed by Joseph Rivet.
Compliance program pulse check
Seven items a program should be able to show. If an item has no owner, it is not operating.
Learn moreCredentialing before the service
A public settlement over services furnished before enrollment. Read it as a fact pattern, not as advice for your enrollment.
Learn moreAccess to records
OCR’s access-right settlements, including a mental health center penalty for a late response.
Learn moreWire-transfer process gaps
A small payment-process hole can move real money. The firm’s 2026 note is about the control, not a form.
Learn more
Experience behind this page
Reviewed by Joseph Rivet, Esq.
Founder, Rivet Health Law, PLC
Joseph Rivet’s compliance counsel sits on the same operations background as the coding and reimbursement work. The question he starts with is whether the program describes the claims this organization actually submits.
Last reviewed October 1, 2026. This page is general information for healthcare organizations. It is not legal advice and does not create an attorney-client relationship.
Who this is for
Who uses this center
- Practices that have a manual and no owner
- Hospitals preparing for a contractor or privacy inquiry
- Billing companies whose contracts require audit cooperation
- Leaders who want a plain list of what “operating” looks like
First pass
First steps you can take today
These steps organize the question. They are not a substitute for counsel.
- 1
Name the person who owns compliance this month.
- 2
Open the standards and see whether they mention your top billed services.
- 3
Find the date of the last training for coders and clinicians.
- 4
Look for one monitoring sample with a reviewer’s name on it.
Published cases are not your result
Several Insights describe public settlements and indictments. They are teaching examples from the public record. They are not outcomes Rivet Health Law obtained, and they are not a prediction about another provider’s exposure.
If a letter names your organization, use the checklist to preserve the file and the deadline. Do not treat a news note as the response.
What “operating” means on this page
Written standards that mention the services you bill. A person the staff can name. Training in the last year for the people who document and code. A monitoring sample someone actually reviewed. A way to record an issue and a refund. Those are the pulse-check items. Missing one is information, not a score.
Sources
How this page was prepared
Joseph Rivet, Esq. reviews these resource centers. The reading list cites the firm’s own Insights and the public CMS materials those Insights discuss. A newer Insight controls if an older note conflicts with it.
Reading
Insights on this topic
Compliance lessons from a public Medicare fraud case
A published case used as a lesson. Not a firm result.
Read
Uncredentialed dental services settlement
Why enrollment dates belong next to the date of service.
Read
OCR and access to medical records
Access-right enforcement. Confirm current OCR guidance before you set a timeline.
Read
CMS fraud and abuse training
A training resource note. Completion is not a compliance determination.
Read
More from the archive
Common questions
- Does a written policy mean we are compliant?
- No. A policy that nobody trained on, and that does not match the claims you submit, is a document. The pulse check asks who used it.
- Should we copy a settlement’s facts onto our program?
- No. A public resolution describes someone else’s allegations and payment. Your codes, contracts, and chart are the file that matters.
- Where is the privacy letter list?
- The checklist page includes the week-one list from the regulatory guidance practice page: preserve the letter, the systems, and the deadline.
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Program pulse check
7 itemsCan you show these seven things this month?
If an item has no owner or no last-used date, it is not operating. This list is a mirror, not a certification.
Check items off as you collect them. Your progress is saved on this device.
This sheet is a gather list for your own file. It is not legal advice.
Related counsel
Compliance counselPrograms built around how the organization actually operates.OpenOther resource centers
When you want help
Bring the letter, the remittance, or the agreement.
If a note on this page raised a question about your file, the firm can sit with it.
This page is educational. It is not legal advice and does not create an attorney-client relationship. Facts, contracts, and appeal windows control the next step.