Compliance program guide

Program Structure A Compliance and Ethics Program Structure creates various levels of oversight by knowledgeable individuals to ensure that applicable policies and written standards of control are followed. Best Practices Define the scope of your industry-specific, risk-based compliance program Document your compliance program strategic plan and obtain leadership approval Identify dedicated compliance personnel or personnel who accomplish compliance program functions Create a compliance budget.

Education Content : Complete Annual Compliance Training Identify and complete industry-specific training mandated by industry, regulations or legislation Identify and complete training that supports employee development and aligns with strategic goals Provide training on new and revised policies, as requested or needed.

Communication: Communicate compliance events policies, training, initiatives, industry changes Offer communication in multiple formats email, website, intranet, newsletter. Culture of Integrity Duty to ensure that senior leadership models and rewards high ethical behavior by delegating authority, hiring, and promoting others with a proven record of high character. Best Practices Promote a Speak Up, Speak Out culture Reinforce the importance of compliance and ethics and obtain leadership support Define specific compliance and ethics expectations Assess employee perception of culture using culture surveys Work with key stakeholders to remediate cultural issues.

Best Practices Monitoring: Conduct wellness checks via telephone, video call, or live to promote a culture of integrity and appreciate employees who demonstrate ethical behavior Maintain a database of applicable laws and regulations and track changes, as needed If red flags appear, report the issue using the established reporting mechanism.

Auditing: Collaborate with the Internal Audit function to ensure that the compliance program meets industry standards Reporting: Maintain an anonymous hotline for employees to report misconduct Create multiple channels for employees to report misconduct Communicate the importance of speaking up and protections i. Internal Investigations Expectations are met through effective checks and balances and taking consistent and appropriate disciplinary measures to discourage unethical conduct while also rewarding those who demonstrate ethical behavior.

This refers to the independence and competence of the investigators, communication regarding investigations, and appropriate response to identified compliance concerns.

Developing and implementing an effective compliance program is critical for healthcare organizations in order to identify areas of risk and respond to issues as they arise. While OIG compliance guidance cannot fit every compliance program framework, healthcare organizations can apply these metrics based on their risk areas, size, resources, and industry segment. Furthermore, applying appropriate elements from the Resource Guide helps organizations demonstrate that they are taking necessary measures to meet their goals and mitigate penalties in the event that problems do emerge.

Apart from OIG compliance guidance, healthcare organizations can use other resources when developing compliance programs, such as specific compliance program guidance documents, OIG Work Plan active items , and corporate integrity agreements. Also, healthcare organizations can further simplify compliance challenges with exclusion screening software and reduce potential risks while setting higher standards when it comes to adhering to the OIG standards. OIG Compliance Guidance Background Developing and implementing an effective compliance program is critical for all healthcare organizations, and to help them create and maintain such programs, OIG issued a Resource Guide for Measuring Compliance Program Effectiveness.

Screening and Evaluation of Employees, Physicians, Vendors, and Other Agents The questions in this section focus on how well organizations evaluate employees, vendors, and affiliated individuals for possible exclusion and conflicts of interest, and whether they have a plan for responding to these issues.

Use this detailed guide to stay ahead of different rules, regulations, and standards that apply to healthcare organizations and find the best approach to building an effective healthcare compliance program. Monitoring, Auditing, and Internal Reporting Systems An integral part of a compliance program is evaluating the effectiveness of processes for monitoring violations of laws and regulations, an internal reporting system for noncompliance, as well as risk assessments and compliance audits.

Investigations and Remedial Measures This section of OIG compliance guidance includes metrics that organizations may use to evaluate the effectiveness of compliance investigations.

Putting OIG Compliance Guidance to Use Developing and implementing an effective compliance program is critical for healthcare organizations in order to identify areas of risk and respond to issues as they arise.

The information contained within this document is general in nature and is not intended and should not be construed as legal, HR, or opinion by Emtpech. With Convercent, you can make sure your compliance risk assessment is robust and aligned with the U.

Compliance risk assessments are easy with Convercent products that give you:. Inside our FSGO guide, available for download to the right, you can gain insight into the most commonly used framework for ethics and compliance program effectiveness. Download the guide to cut risk down in your organization and put a sound process in place for your compliance risk assessment activities.