Fluent Essays

(PLEASE SEE MY ATTACHMENTS, ITS SUPPOSED TO HELP)  1. Since 1998, the Office of the Inspector General (OIG) has been strongly recommending that all health care organizations adopt 7-part compliance programs. The enactment of the 2010 health reform law (Patient Protection and Affordable Care Act) changed that in a very significant way. What was the change? 2. What is the connection between the Federal Sentencing Guidelines and the OIG Compliance Program Guidance’s? 3. What are the 7 basic components of a now mandatory compliance program? (Being familiar with these components is essential - especially on an interview for a compliance position!) 4. Describe three attributes of the position of the Compliance Officer in an organization. 5. Identify five functions performed by the Compliance Officer. 6. There are four steps to follow when an organization learns of possible non-compliance. What are they? Chapter 8 Compliance Programs in General Learning Objectives (I) Benefits of a comprehensive compliance program Contribution of Federal Sentencing Guidelines 7 standard compliance program components Roles of Compliance Officer and Committee Purpose of compliance policies and procedures Outline of a compliance training initiative Learning Objectives (II) Open communication channels for questions and complaints Compliance auditing and monitoring methods Disciplinary program for employee misconduct Investigation of suspected non-compliance Introduction In order to ensure obedience to the large and growing number of laws impacting health care, every health care entity must have a compliance program. Such a program is an infrastructure of rules, trainings, penalties, and response protocols that reduces the incidence of non-compliance, detects it faster when it happens, and prevents its recurrence. Introduction Under the PPACA of 2010, compliance programs are mandatory. Benefits of a Compliance Program (I) Prerequisite to Medicare program participation Demonstrates good corporate citizenship Method for eliminating misconduct and illegal behavior Clearinghouse for information on legal and payor requirements Encourages employees to report misconduct Protocol for investigating and resolving misconduct Benefits of a Compliance Program (II) Reduced exposure to a wide range of civil and criminal legal penalties Enhanced public image and reputation Required improvement in operations Insight into employee attitudes and behavior Ability to react to reports of misconduct Better cooperation among health care entities Employees empowered to question and report 7 Components of a Mandatory Compliance Program Written standards of conduct, policies & procedures Designation of Compliance Officer & Committee Regular compliance training programs Open channels to receive questions & complaints Ongoing audits and monitoring for effectiveness Disciplinary action for violations & non-compliance Investigation and corrective action for non-compliance 8 Compliance Officer Single person with overall responsibility for management of the compliance program Full-time job, reports directly to CEO, and has access to the governing board Coordinates investigations of misconduct and resulting corrective actions Interacts with legal counsel and government agencies on compliance matters Compliance Committee Advisor to Compliance Officer, hear appeals of his decisions, perform more substantive tasks Composed of people from compliance-related areas (legal, billing, personnel, security) Written Standards, Policies and Procedures Guide the conduct of organization and employees in day-to-day operations Provided to employees, physicians, and agents #1 Code of Conduct #2 Policies and procedures describing general principles of work behavior #3 Policies and procedures describing job performance in high compliance risk areas Code of Conduct A kind of “constitution” stating the basic values and principles that employees are expected to follow Should be brief, quickly understood, memorable, and applicable to all employees and agents Reflection of the character of the organization Code of Conduct Sign to the public of the organization’s good citizenship and worthiness as a source of health care good or services Tells suppliers, vendors, agents that organization is a high-integrity, trustworthy business partner General Policies and Procedures States organization’s commitment to abide by the external requirements and constraints imposed on it, including laws focused on the health care industry, other laws (employment discrimination, environmental protection) that apply to all businesses, and the requirements for participation in Federal health care programs like Medicare and Medicaid. Specific Policies and Procedures Tells employees working in areas at high risk of non-compliance how to perform their jobs. The OIG Program Guidances describe risk areas for each type of health care organization and suggest policies to address the risks. Review guidances from exemplary health care organizations like hospitals or physician practices. Implementation of Standards, Policies, and Procedures Must be communicated to and understood by employees who will apply them. Take into account employees’ languages, education levels, and backgrounds. Know basic compliance principles by heart. Employees acknowledge their receipt and understanding of the rules, and their agreement to follow them. Compliance Education and Training Appropriate training to employees when first hired and at regular intervals thereafter Curriculum topics – basic and advanced Training attendance is condition of employment & a factor in evaluations Directed at all employee levels of organization Try to reach vendors and contractors as well Use variety of teaching methods Communication Channels for Questions and Reports Employee seeks compliance clarification Employee reports of suspected misconduct Work environment that encourages employees to talk about problems Multiple channels for compliance reporting Employee reports kept confidential, no retaliatory discipline Publicize the communication channels Monitoring and Auditing of Compliance Activities Monitoring - persistent review of activities in the course of normal day-to-day operations Auditing - more formal, discrete review of compliance with a select criteria What activities to monitor or audit Methods for gathering operational data relevant to compliance Using the data gathered by monitoring and auditing Disciplinary Action Against Non-Compliant Employees Range of culpability for non-compliance Investigate incidents Stop the non-compliant activity Identify responsible persons Take appropriate disciplinary action Formal system for administering discipline Ensuring compliant behavior of agents Investigation Followed By Corrective Action Prepare protocol for conducting investigations Person to lead & conduct the investigation When attorney and experts get involved Evaluating investigation progress and ending it Protecting information security and anonymity of individuals involved Decision on corrective action Possible Corrective Actions Discipline of employee, termination of agent K Repayment of overpayments received Report of non-compliance to government Report incidents to law enforcement agencies Reengineer faulty internal systems Revise education and training curriculum Retrain relevant personnel or hire new ones Modify existing policies and procedures Health Care Industry Compliance Practices Compliance training is mandatory Most common training methods Measure compliance program effectiveness Set goals for compliance programs Areas covered by compliance programs Organization status of Compliance Officer Compliance Committee responsibilities