It's Time to Review Your Compliance Plan!

PUBLISHED: Nov 29, 2016

In the last two weeks StayAlert! has reviewed the Office of Inspector General’s (OIG) 2017 Work Plan. The Work Plan gives health care organizations insight into areas that OIG will be focusing on for the upcoming year. OIG aims to protect the integrity of US Department of Health and Human Services (HHS) programs and operations and the well-being of beneficiaries by detecting and preventing fraud, waste, and abuse; identifying opportunities to improve program economy, efficiency, and effectiveness; and holding accountable those who do not meet program requirements or who violate Federal health care laws.

With an understanding of where OIG is focusing its resources in the upcoming year, now is an excellent time to review your organization’s compliance plan to ensure all essential components are addressed. As StayAlert! has previously reviewed, any hospital that receives federal funds is required to establish and maintain a comprehensive compliance program.

According to guidance from OIG, key components of a compliance program include:

  • Demonstrated commitment to honest and responsible corporate conduct.
  • A program that increases the likelihood of preventing, identifying, and correcting unlawful and unethical behavior at an early stage.
  • A program that encourages employees to report potential problems to allow for appropriate internal inquiry and corrective action.
  • A program that minimizes financial loss to government and taxpayers, as well as any corresponding financial loss to the hospital through early detection and reporting.

Health care organizations should have a dedicated compliance committee, under the oversight of the hospital’s compliance officer that is responsible for developing and implementing a comprehensive, organization-wide compliance plan. The plan should include:

  • Policies and procedures addressing compliance areas
  • A compliance-focused employee education program that is:
  • Conducted at hire and then least annually thereafter.
  • Reviews all applicable Federal and state laws and regulations that apply to and impact the organization's documentation, coding, billing and competitive practices, and the day-to-day activities of the hospital and its employees and agents.
  • Is specific to the organization and includes general information on compliance issues and well as individual departmental training on specific risk areas.
  • Attendance at the compliance education program should be documented in the employees personnel file.

Included with today’s notice are example policies and procedures related to the development and implementation of a comprehensive compliance plan.

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