In recent years the healthcare industry has seen a tremendous push in its efforts to encourage organization(s) to develop effective internal controls to monitor compliance with State and Federal regulations. As hospitals and other healthcare organizations continue to face increased scrutiny, Provident has developed a checklist that can be used to determine where your organizations compliance program stands on the effectiveness scale.

Compliance Program Background:  Efforts for enhanced compliance and transparency came to the forefront in 1998 when the Office of Inspector General (OIG) established voluntary guidelines for hospital compliance programs. The OIG has since established a series of voluntary compliance program recommendations directed at various segments of the healthcare industry. In line with OIG guidance, in 2004, the Federal Sentencing Guidelines (FSG) were revised to include standards essential to an effective compliance and ethics program. Adherence to the voluntary guidelines provided by the OIG and the FSG greatly reduce an organizations risk and minimize the consequences should an adverse event occur.

Compliance Program Effectiveness Checklist:  Provident has significant experience working with healthcare organizations looking to implement or enhance an existing compliance program. Provident’s unique implementation / assessment methodology takes into account voluntary guidance and market experience to ensure facilities are operating at the highest level of compliance program effectiveness. The below excerpt of a compliance program checklist can be used to assess the effectiveness of your program:

• Does your organization have written policies and procedures?
  • Are they endorsed by senior leadership and/or approved by the Board?
  • Do they address employee and management adherence to compliance, including non-compliance repercussions?
  • Do they address specific areas of potential fraud, misconduct and intentional and unintentional false claims?
  • Are they regularly reviewed and revised to reflect new regulations?
• Does your organization have appropriate compliance oversight?
  • Does your organization have a compliance officer and/or individual who is directly responsible for operating and monitoring compliance and ethics within the organization?
  • Does the named individual report directly to the CEO or Board?
  • Does your compliance staff have access to technical resources to effectively audit complex clinical documentation and coding for compliance issues?
• Does your organization complete education and training?
  • Is the education and training ongoing?
  • Are all impacted employees educated and trained?
  • Are high risk employees provided with extensive training?
• Is there a formal process of continuous improvement where the outcomes and mitigation of audits, investigations and external industry events are factored into ongoing risk assessment, training and monitoring?

These questions are a good starting point to determine where your organization stands in regards to the effectiveness of its compliance program. For more information, related to establishing an effective compliance program please contact contact@providentedge.com.