OIG Effective Compliance Program -
The Seven Basic Elements
by A. Maureen Hanna
OIG Effective Compliance Program -
The Seven Basic Elements
by A. Maureen Hanna
Element # 2 - Designating a Compliance Officer and Compliance Committee
It is the Office of Inspector Generals (OIGs) belief that every Durable Medical Equipment, Prosthetics, Orthotics & Supplies (DMEPOS) should designate a compliance officer to serve as the focal point for compliance activities. This individual should be a person of high integrity.
The responsibility of a compliance officer may be the individuals sole duty or added to other management responsibilities (depending upon the size and resources of the supplier and the complexity of the task). When a compliance officer has other duties, the other duties should not be in conflict with the compliance goals.
Designating a compliance officer with the appropriate authority is critical to the success of the program. The individual needs to have direct access to the owner(s), president or CEO, governing body, senior management, and legal counsel. It is the OIG's belief that the compliance function should not function as a subordinate to the general counsel, comptroller or financial officer. This is to help ensure independent and objective legal reviews and financial analyses of the compliance efforts and activities.
A compliance officer's primary responsibilities should include:
...Overseeing and monitoring the implementation of the compliance program;
...Reporting on a regular basis to the owners(s), governing body, CEO, president and compliance committee (if applicable) on the progress of implementation, and assisting these components in establishing methods to improve the supplier's efficiency and quality of services, and to reduce the vulnerability to fraud, abuse and waste;
...Periodically revising the program in light of changes in the organization's needs, and in the statutes, rules, regulations and requirements of Federal, State and private payer health care plans;
...Reviewing employee's certifications they have received, read, and understood the standards of conduct;
...Developing, coordinating, and participating in a multifaceted educational and training program that focuses on the elements of the compliance program;
...Ensuring independent contractors and agents are aware of the supplier's compliance program;
...Coordinating personnel issues with the Human Resource/Personnel Office;
...Assisting the financial management department in coordinating internal compliance review and monitoring activities;
...Independently investigating and acting on matters related to compliance;
...Developing policies and programs that encourage employees to report suspected fraud and other improprieties without fear of retaliation;
...Continuing the momentum of the compliance program.
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