YOUR ONE-STOP SHOP FOR CORPORATE COMPLIANCE PLANS
|Ten of the Most Essential Points For Writing a Successful Compliance Program
1. Leading from the Top
As a Corporate Compliance Plan writer and consultant, we also work with many other compliance professionals and ethical organizations in healthcare and use the resources available with federal and state governments including the Office of Medicaid Inspector General, the Centers for Medicare and Medicaid Services (CMS) among others.
We are seeing more and more government audits and it is critical that firms have their CCP ready to respond an any given issue and be able to show that you are acting in a good faith effort. CCP’s do not have to be extensive in length but must incorporate the essentials ten points above. It is critical to have leadership from the board and senior management who support and develop a culture of compliance, integrity and ethical standards and set an example for all employees and stakeholders.
Fraud, Waste and Abuse are a major theme with the government. Having your CCP documented in writing is an important step but it takes the leading role of a qualified Compliance Officer to make it happen on an every day basis. It is a full-time effort regardless of size of your firm. Legal counsel can be of help but the Compliance Officer need retain an independent role and also monitor areas such as governance, quality, credentialing, audits and other risk areas.
Training and Education not only help employees, management, board, vendors and the like learn about the CCP but is designed to re-enforce regularly the Compliance Office work and availability. Communication, through a helpline or hotline, is very important and to encourage people to call in a safe and secure environment without fear of retaliation or intimidation. The use of the many social media sites presents communication challenges and needs to be a part of every CCP. The role of disciplinary actions and rewards are essential components in having written policies and procedures in order to protect your firm.
Identifying risk through quality care, audits, data analysis, exclusion lists of Medicare and Medicaid, conflict of interest, self-disclosures and conducting prompt investigations are necessary component parts in developing your CCP. The more active your plan, the greater number of cases should occur. This is a positive as it resolves situation before they can developed into larger and more complex issues. Your firm can become more productive, efficient and effective as a result of the CCP.
|Are You Ready to Get Started On Your Corporate Compliance Plan?
How is the state of your organization’s Corporate Compliance Program (CCP)? Is it written, current, approved and a part of your company culture? How often do you review it? Are recent federal and state legislation a part of it? Is your program regularly assessed for its effectiveness? Are your employees, board, stakeholders, department heads, vendors aware of its provisions? Is the program being used? Is it active? How many cases did you have this past quarter of year? Are there conflicts with management and legal? These are some of the questions that need to be addressed in order to demonstrate an effective compliance program (CCP). For over fifteen years, the role of a CCP and the organization’s compliance and ethics officer has been growing. It was once considered a part-time area for selected individuals but now has grown into full-time responsibility and profession.
From the federal Office for Medical to Inspector General guidelines issued in 1997 to the Sarbanes-Oxley in 2002 to the Affordable Care Act of 2010 and state mandates from the Deficit Reduction Act in 2005 and the False Claims Act, the corporate compliance field has elevated the importance of having an effective compliance program to critical levels. This growing movement, led by both federal and state governments, has seen CCP’s grow into its own especially with a number of high profile settlements and ethic cases.
At the same time, the CCP and the Compliance Officer may appear to senior executive management as a potential challenge to their role or control of what the board vision. The purpose of any CCP is make sure that the firm are providing their goods and services in a lawful and ethical manner for the benefit of the entire organization.
Our services are designed to help healthcare and other industries, non-profit and for-profit, private or public, to encourage self-examination and continuous compliance improvement for all by fostering a positive, efficient, essential and effective CCP at a reasonable cost to your organization and become certified by the government.