Before considering compliance activities or team roles, review strategies for implementation and monitoring; the wrong approach will make or break your practice, especially if you are subject to an OIG investigation.
Remember, the OIG can tell who left their compliance plan on the shelf “to collect dust.” Ensure it is fully functioning and your employees are following it verbatim.
To start, the OIG Federal Register, created in the year 2000, is the suggested guide all practices should utilize when building an effective compliance program.
In this Register, the OIG provided a list of six strategies to start your team on the road to success. The team strategies are:
Oversee and monitor the implementation of the compliance program.
Establish methods, such as periodic audits, to improve the practice’s efficiency and quality of services and reduce the practice’s vulnerability to fraud and abuse.
Develop, coordinate, and participate in a training program that focuses on the compliance program components and ensures that training materials are appropriate.
Ensure the HHS-OIG’s List of Excluded Individuals and Entities and the General Services Administration’s (GSA’s) List of Parties Debarred from Federal Programs have been checked regarding all employees, medical staff, and independent contractors.
Investigate any report or allegation concerning possible unethical or improper business practices and monitoring subsequent corrective action and/or compliance.
Periodically revise the compliance program per changes in standards or laws that affect your practice (i.e., HIPAA, OSHA, etc.).
As always, tailor the strategies to your specialty. And, in my next post, I will discuss how to reinvent your team based on these strategies.
**The opinions and observations from the group/author are not a promise to exempt your practice from fines and penalties. Research, modify and tailor the advice to fit your specialty.
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