If You’re a Healthcare Provider (Whether a Hospital, Skilled Nursing Home, Home Health, Clinic or Physician), You Need to Make Corporate Compliance a Part of Your Company Culture. Here’s How to Get Your Hands on The Ultimate Corporate Compliance Plan Summary Guide…

The New York State healthcare industry is subject to a plethora of statutory rules, regulations and mandates.  In response, healthcare providers, ranging from hospitals, skilled nursing homes, home health, clinics and physicians, are making corporate compliance a part of their company culture.

It does not matter if an organization is a for-profit or not-for-profit.  The over-arching goal is to providing the best in quality of care to patients and residents; have a means of prevention to detect and identify areas that may be at risk of non-compliant; and to remove wasteful business activities resulting in greater productivity.

The growth is compliance programs take a sharp turn upward with the federal and state adoption of the False Claims Act of 2007 and subsequent legislation including the Center of Medicare and Medicaid’s Recovery Act Program, the creation of the NYS Office of Medicaid Inspector General and the health care reform act of last year.  Compliance plans, also known as Integrity, Ethics or Corporate Responsibility, despite the government mandates, do provide businesses the best opportunity to thrive and prosper – and it’s not just limited to healthcare organizations!

Compliance plans are best known as a series of codes of conduct for all employees including board of directors, management and vendors.  These policies and procedures set-up the core structure of an organization in tandem with the firm’s mission and vision of future growth and acts as a way to resolve work issues of concern promptly.  .

What are some of the key ingredients of an active and effective corporate compliance plan?  From my own experience and government sources, here are my top ten essentials:

1. Leadership from the Top: The organization endorsement and active support is crucial to the success of a compliance plan.  It sets the tone and develops trust by encouraging participation.
2. Documentation:  Have it in writing for all involved and to review and update it at least one a year.
3. Compliance Integrity Officer: Assign an employee as the compliance officer, who must be properly trained and credentialed, in order to identify practices that may be costly to the firm; keep current with legislation; and report at least quarterly to the CEO and any board.
4. Training: Educate and train employees and all stakeholders of the company regularly and to be prepared for government inquiries or surveys.
5. Communication: Technology advancements has given us smart phones, iPads, iPhones, etc. direct face-to-face meetings are most important.  Have a separate office and phone line to discuss topics and encourage contact.
6. Social Media: Have separate written policies regarding the use of any company information when it involves LinkedIn, Twitter, Facebook, etc.
7. Disciplinary Component: encouraging good faith participation by have compliance a part of an employee evaluation.
8. Identify Risk: Regularly self-evaluate areas with audits, mandatory reporting, conflicts of interest, governance, credentialing, quality assurance and the like.
9. Risk Response: When an issue surfaces, have a response system ready to promptly address it.
10. Non-Retaliation: Assure your employees that by coming forth to the compliance office that it will not result in any retaliation or intimidation.

Compliance programs are reliant upon people to participate in it for the benefit of the entire organization.  It needs to be pro-active, embraced by from the organization’s leaders and to identify risk areas.  By doing so, it can result in early resolution of  unidentified revenue, under performance, unfavorable trends or patterns, lack of communication and unnecessary costs.

Take a lot at your program.  If you do not have one, review the essentials listed above, then delve deeper into creating an effective  Corporate Compliance Plan by getting immediate access to the Ultimate Corporate Compliance Plan Summary Guide.

Government agencies believe that it is a best practice for healthcare providers to perform, at a very basic level, an annual review of the effectiveness of their compliance programs.

This guide was created to be a compliance builder for your own organization and takes into account your size, mission, issues, complexity and the overall sophistication of your corporate compliance plan.

Hiring a consultant to help with this is well worth it, and this guide will be your first step to discovering what makes a good consultant, and what makes an effective Corporate Compliance Plan.

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