We all can agree a plan is the best way to prepare and set minimum standards. In healthcare, compliance plans not only stand as best practice but for some healthcare sectors they stand as a requirement. A compliance plan sets the tone, rules and confirms what matters for your culture. Compliance planning requires the involvement of multiple departments and key stakeholders.


We have had a lot of conversation in our office recently about the importance of choosing the correct exclusion monitoring vendor for your organization. These conversations reminded us of the key takeaways – aside from the Britney Spears concert – from the National Association of Rehabilitation Facilities (NARA) that was hosted in October 2015 at Las Vegas.

Remember –

There are 7 elements that make an effective compliance plan. The elements surrounding effective monitoring was a topic covered at the NARA. Some of the nation’s leading owners of rehabilitation facilities gathered to network and learn about current trends and legal issues affecting the industry.

More than 100 rehabilitation leaders attended the annual conference in Las Vegas. The vibe of the conference was felt throughout and many hardworking leaders of rehabilitation facilities were eager to learn about best healthcare compliance practices.

We spoke about how to effectively monitor employees, vendors and referring physicians for exclusions and license status. The NARA members were guided through a who, what, when and why of OIG exclusions and learned how the OIG is imposing fines for non-compliance in this healthcare vertical – just as it does for hospitals, long term care facilities and clinics.

NARA takeaways –

– Does your company have a compliance plan?
– How many hours of compliance training actually occurred?
– What PII identifiers (and how reliable) are in the data set to be searched?
– Are all employees (including non-licensed), vendors and referring physicians monitored?
– How often and thorough is an audit of OIG exclusion monitoring audited?
– Did company self-disclose if determined that an excluded party found?
– How often are federal and state exclusion lists monitored? If at all.

These key points talked about at NARA reminded us of how important it is to choose the correct vendor for monitoring exclusions in your organization.

Mostly, we learned the most important aspect of compliance is to:

compliance plan

This post was originally published October 20, 2015 and has been completely revamped and updated for accuracy and comprehensiveness.

You might also enjoy:
Ben Franklin was Right: $1 saves $179,000 and prevents OIG exclusions
What you didn’t know about Unlce SAM(.gov)
How to get off the OIG Exclusion List
OIG compliance program guidance for hospitals

Michael Rosen, ESQ

Written by Michael Rosen, ESQ
ProviderTrust Co-Founder, mrosen@providertrust.com

Michael brings over 20 years of experience founding and leading risk mitigation businesses, receiving numerous accolades such as: Inc Magazine’s Inc 500 Award and Nashville Chamber of Commerce Small Business of the Year
Connect with Michael on Linkedin

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