OIG
Effective Compliance Program - Element # 1
(Part One)by A. Maureen Hanna
OIG
Effective Compliance Program - Element # 1
(Part One)
by A. Maureen Hanna
In last month's issue we spoke of the seven elements that the Office of Inspector General has determined are fundamental to an effective compliance program for the DMEPOS industry. Beginning with this issue, we shall cover the seven elements in more detail and provide you with tips your organization can follow to implement these guidelines within your organization.
Element # 1 - Implementing written policies, procedures and standards of conduct
Each compliance program should require the development and distribution of written compliance policies, standards, and practices that identify specific areas of risk and vulnerability to the individual supplier. These should be developed under the direction and supervision of the compliance officer and the compliance committee (if practicable and applicable).
The standards of conduct should be developed for all affected employees and include a clearly defined commitment to compliance by senior management (e.g. owners, CEO, president, VP etc.) including any related entities or affiliated providers operating under the supplier's control (e.g. RN, RT, physicians, etc.). The standards should articulate the supplier's commitment to comply with all Federal and State statutes, rules, regulations, and Federal, State and private payor health care program requirements, with an emphasis on preventing fraud and abuse.
Tips:
1. State the organizations mission statement,
goals, and ethical principles relative to compliance.
2. Clearly define your commitment to compliance and your company's
expectations of senior management.
3. Promote integrity, support objectivity, and foster trust.
4. Set forth broad principles that guide employees in conducting
business professionally and properly.
5. Distribute to all affected employees.
6. Translate into other languages (if necessary) and write to
employees' appropriate reading level.
7. Regularly update the standards of conduct (e.g. employee handbook)
8. Ask employees to sign a statement certifying that they understand
the standards of conduct.
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