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The importance of an effective compliance program cannot be overstated. It protects your organization against fraud, abuse, waste, and other potential liabilities. But it doesn’t stop there. A quality compliance program is also paramount to quality patient care because the wrong motives rarely result in the exceptional care necessary to stay competitive in this day and age.
The simple truth is that a poorly designed or imperfect compliance program will cost you but taking a thorough self-assessment compliance quiz is totally free. And our quiz is thorough. While the OIG has their 7 elements of an effective compliance program, we take it even further with a few additional crucial elements. Our 10 elements will ensure that your program isn’t just compliant, but that you’re exceeding set standards and excelling in your industry. The 10 elements of a stellar compliance program are:
- Assessments: The OIG has established that a risk assessment is required for an effective compliance program. Best practices suggest that a risk assessment should be a formal process to prioritize risks (conducted according to a customized framework that represents your risk landscape), embody a well-thought-out implementation methodology, and utilize a scoring methodology.
- Workplan: Every organization should utilize the results of their risk assessments and updates from governing bodies (e.g. - OIG, OCR) and develop a comprehensive workplan for each fiscal year. Organizational workplans should be thorough, include action items, and the delegation of responsibilities on how to approach and solve any real or perceived weaknesses in your compliance program.
- Training: Your organization should have mandatory annual compliance training, and your assessment and competency results should influence your education improvement plan and goals. It’s ideal for you to leverage technology and innovation in your education design and delivery. And your operations should provide input into plan development and assessment.
- Policies: Your organization should employ technology to implement a single policy management system and have developed policies leveraging multi-disciplinary workgroups with subject matter experts. Or, at the very least, implemented a standardized approach for policy development, management, and oversight and have leveraged technology to track and report policy review and revision metrics.
- Incidents: Government resources believe successful incident management must include the availability of a hotline or reporting mechanism, consistent treatment of all reports, and thorough investigations. You should consider every reported incident a potentially serious risk and implement technology and/or tools that document the incident management process. Be sure your technology includes a root cause analysis, corrective action plan, and rules for enforcement and discipline.
- Audits: In order to manage audits effectively, you should have a defined audit plan that recognizes ownership and accountability of audits and the issues that are being audited. Compliance and auditing departments should develop an audit plan and include input from senior leaders and the governing body. The audit plan and all individually targeted audits should be conducted, combined, tracked, and recorded utilizing technology that allows data analytics and predictive analytics.
- Sanctions: Exclusions monitoring is mandatory. For a compliance program to be truly effective, organizations that receive reimbursement for services submitted to Medicare and Medicaid are required to run monthly checks against all the exclusion lists to ensure that none of their employees are excluded and that no entity that they do business with is excluded. This includes contracted workers and affiliated physicians/individual licensed practitioners. The prosecution of this falls primarily under the False Claims Act.
- Governance: Staying current with compliance requirements demands a compliance program to monitor changes in laws, regulations, and administrative rules. Best practices require that organizations leverage sophisticated processes, or technology, to identify regulatory changes and create action plans in a timely manner.
- Contracts: Due to the abundance of controlling laws and regulations, organizations must meticulously manage contracts and suppliers. And contract management includes physician contracts, physician leases, supplier contracts, and business associate agreements. All contracts should be organized and housed in a repository that allows easy monitoring and regular reviews, which provides automated notices. Tracking critical contract terms and reviewing them regularly provides protection from Stark Law violations, HIPAA business associate violations, breaches, subsequent OCR investigations, and Anti-Kickback violations.
- Reports: In order to ace compliance, governing bodies and senior leaders should be aware of and consistently involved with your compliance program. However, Compliance Officers must report directly to the governing body or corporate compliance committee and not through the legal department or the CEO. Ideally, you should be reporting to your governing board at least quarterly and provide comprehensive reports that detail compliance efforts and progress, such as your organization's risk mitigation plan or workplan, recent incident management activities, newly discovered issues or risks, and policy updates.
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Each of the ten questions provides a thorough background on an element. It only takes a second to self-select how your organization is doing in each department. For examples, see the first question above for assessments. You simply select, “awesome,” “pretty good,” “needs work,” or “uh-oh.” Once you’ve selected the option that best fits your organization, you go on to the next question. There are ten questions total and after you’re finished you’ll instantly receive your results along with free expert feedback. Yes, it really is that simple to upgrade your compliance efforts.
In the words of Beyonce, “let me, let me, upgraaaade you.”
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