To create effective compliance programs, healthcare providers and officials must focus on four major principles, according to new guidance from the U.S. Department of Health and Human Services' Office of Inspector General (OIG).
Fraud crackdowns mean corporate compliance matters more important than ever; as boards' compliance program oversight takes a more prominent role in healthcare governance, it's vital for them to understand the process' guiding tenets. OIG collaborated with industry leaders to develop guidelines based on earlier Corporate Integrity and Settlement Agreements. They include the following:
Define your audit, compliance and legal departments' jobs and relationships with one another. Healthcare leaders, the guidance states, must pin down each department's responsibilities and boundaries, making note of each one's independence and performance. Each department should understand the part it plays in the compliance process and communicate with one another.
Assess the organization's protocols for gathering information and reporting issues. Hospital boards should require each compliance-related sector to independently report on its compliance and risk-management efforts. The guidance recommends scorecards measuring such areas as implementing compliance programs, identifying and dealing with risks and taking corrective action.
Identify and audit potential risk areas. These could include common vulnerabilities in healthcare systems, such as referral arrangements, billing issues or privacy breaches. Boards should also establish clear processes for risk identification. "Audits and monitoring can help identify potential risk factors and compliance concerns," the guidance states. "Audits that identify compliance risks should be followed with corrective action plans."
Encourage compliance throughout the enterprise. To do this, OIG recommends regular performance assessments, which boards can reinforce by withholding incentives or awarding bonuses. Healthcare providers should also take the initiative to inform OIG of any violations of the law under the OIG's Self Disclosure Protocol; this will lead to lower payment, speedier resolution and release from further compliance obligations.
To learn more:
- read the guidance (.pdf)