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 # 4 - Developing Effective Lines Of Communication
An open line of communication between the compliance officer and DMEPOS supplier employees is important to the successful implementation of a compliance program. It can reduce any potential for fraud, abuse and waste of federal program funds.
Written confidentiality and non-retaliation policies should be developed and distributed to all employees to encourage communication and the reporting of incidents of potential fraud. It should also be communicated that there may be a point where the individual's identity may become known or may have to be revealed.
An effective program should have several paths for an employee to seek clarification regarding DMEPOS supplier policy, practice, or procedure. Additionally, to report fraud, abuse and waste. It is important to have several paths so that such reports cannot be diverted by their supervisors or other personnel.
Paths can include:
Hotlines; Email; Written Memoranda; Newsletters; and Suggestion Boxes.
Both questions AND responses should be documented and dated. If appropriate, responses should be shared with other staff so that standards, policies, practices and procedures can be updated.
Communication that suggests substantial violations should be documented and investigated promptly to determine their veracity. In this case, a log should be maintained that includes reports to the owner(s), governing body, the CEO, president and compliance committee, if applicable.
Assertions of fraud and abuse by employees who may have participated in illegal conduct or communicated other malfeasance raise numerous complex legal and management issues. These should be examined on a case-by-case basis. The compliance officer should work closely with legal counsel, who can provide guidance regarding such issues.
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