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 # 5 - Enforcing standards through well-publicized disciplinary guidelines
An effective compliance program should include guidance regarding disciplinary action for corporate officers, managers, employees and other health care professionals who have failed to comply with the DMEPOS supplier's standards. This should include a statement setting forth the degree of disciplinary action that may be imposed for failing to comply with the DMEPOS standards, policies, and applicable statues and regulations.
Such sanctions could range from oral warnings to suspension, termination, or financial penalties, as appropriate.
The written standards of conduct should elaborate on the procedures for handling disciplinary problems and those who will be responsible for taking appropriate action.
The DMEPOS supplier should advise personnel that disciplinary action will be taken on a fair and equitable basis. Management should be aware they have a responsibility to discipline employees in an appropriate and consistent manner. All levels of employees should be subject to the same types of disciplinary action of the commission of similar offenses.
The DMEPOS supplier policies should prohibit the employment of individuals who have been recently convicted of a criminal offense related to health care or who are listed as debarred, excluded, or otherwise ineligible for participation in Federal health care programs. For all new employees who have discretionary authority to make decisions that may involve the compliance with the law or compliance oversight, suppliers should conduct a reasonable and prudent background investigation, including a reference check. An employee involved in pending the resolution of any criminal charges or proposed debarment or exclusion should be removed from direct responsibility for or involvement with, the supplier's business operations related to any Federal health care programs. Additionally, if the position(s) for which the individual's salary or the items or services rendered, ordered, or prescribed by the individual are paid in whole or part, directly or indirectly, by Federal health care programs and/or funds.
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