Although there are many definitions and descriptions of a compliance program at its most basic level it is a method for an organization to ensure that there are methods identified for prevention, detection, collaboration and enforcement of all applicable federal and state laws governing the organization.
An effective compliance program is an ongoing process. It is a system for doing the right thing through policies and procedures that are developed within the organization. By how is that defined?
According to the Compliance 101 resource, the OIG’s top 10 list of reasons to implement a compliance program are as follows:
- Adopting a compliance program concretely demonstrate to the community at large that a provider has a strong commitment to honesty and responsible corporate citizenship
- Compliance programs reinforce employees’ innate sense of right and wrong
- An effective compliance programs helps a provider fulfill its legal duty to government and private payors.
- Compliance programs are cost -effective
- A compliance program provides a more accurate view of employee and contractor behavior relating to fraud and abuse.
- The quality of care provided to patients is enhanced by an effective compliance program
- A compliance program provides procedures to promptly correct misconduct.
- An effective compliance program may mitigate any sanction imposed by the government.
- Voluntarily implementing a compliance program is preferable to waiting for the OIG to impose a Corporate Integrity Agreement (CIA).
- Effective corporate compliance programs may protect corporate directors from personal liability.
Now that you know why you need a compliance program, what does that look like and where do you start? There is not a standard compliance program out there that is appropriate for all organizations but the foundation is a commitment to meeting the 7 seven essential elements that an effective compliance program is structured around and identifying barriers you may encounter.
As you start to examine your compliance program, the first step would be to ask have you reviewed and updated your policies and procedures and provided your employees with standards of conduct? If so, when? Establishing these items will provide a code of conduct for good decision making throughout the organization.