Ever try to build something without a plan or instructions? How did it turn out? Did you just “wing” it or go by a picture in your mind? That may work when you are building a kids’ skateboard ramp or even a dollhouse, but it’s not a good idea for running a compliance program in healthcare!

How an organization develops and implements an effective compliance program –

Good news, bad news:  A compliance plan is just that – a plan. It will be viewed as a foundation from which to base decisions and actions taken by your organization. That’s the good news. On the flip side, it will also be used as a checklist and basis from which to hold an organization liable for following and adhering. That can be the bad news. This means that an “off-the shelf” plan that is copied or duplicated is not the best practice or means to the end.There is no instruction kit or a one-size-fits-all when it comes to building a compliance plan. But the good news is there are many resources publicly available and readily for your use. No reason to re-invent the wheel, but all the reason to spend the time to modify it to your organization and to ensure it covers YOUR plan to comply. 

Get input from all stakeholders –

It is crucial the plan is a culmination of and a reflection of legal, compliance, human resources, operations, finance/billing, I.T., and audit. Each of these departments will have a daily impact and could cause compliance issues if not coordinated. There are so many intricacies and areas for joint coordination so as not to prevent the company from effectively operating as well as performing its duties in compliance with regulations and internal policies and procedures. There are so many moving parts. That is why a plan is so important.

Get the message out –

A plan is just a plan if it is not shared, taught and made a part of the culture. It should therefore be instructive but also written in a way that all staff can understand and follow. If the plan is too legalese than you stand the chance of people not paying attention to the rules or understanding how to meet the plan. This means taking the plan from “Wall Street to Main Street.”

It also means training and refresher courses are vital. Best practice is to include compliance training as an integral part of new employee on boarding as well as annual refresher courses. It also means that if audits demonstrate a lack of understanding or adherence, that you must react by re-training. Failure to act or react can be detrimental.

Summary –

Remember, people want to do the right thing and to be  a part of an organization that believes, talks and walks what it espouses. This means compliance should be at the forefront of the culture. If your CEO leads by example and you can deliver a plan that is instructive, easy to understand, and you couple it with adequate training/audits, you will have an effective compliance plan in 2016 and beyond.

Healthcare compliance programs should be carefully crafted and contain a well thought out plan for compliance, audit and how to respond. In addition, an effective healthcare compliance plan necessitates the input, review and advice from outside experts (attorneys, consultants and/or healthcare experienced managers).  After all, the end result is a reflection of what you stand for as an organization and will be scrutinized by regulators – or even worse – in litigation by jurors or judges.  

Look for other ProviderTrust, Inc. blogs this month for the continuation of this conversation about making compliance part of your organization’s compliant culture. Topics include: onboarding employees, your role to update the board and many more.

For further reading:
OIG Compliance Program Guidance for Hospitals
Healthcare Compliance – Applying Lessons from Kindergarten
A Compliance Plan that Needs Rehab
Healthcare professionals speak on healthcare compliance issues

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
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