Here are a few hospital compliance issues a compliance department must ensure is being met in order to continue to provide quality and legally compliant care:
1. Is the Hospital continuously meeting state, federal and even independent accreditation standards (Joint Commission)?
2. Is the Hospital continuously meeting state license requirements for all of its healthcare professionals?
3. Is the Hospital continuously improving in order to meet CMS and DHHS safety and quality standards?
4. Is the Hospital compliant with its billing protocols?
5. Is the Hospital monitoring for compliance and aware of any potential Stark law and Fraud and Abuse violations?
Inherent in each of these continuous hospital compliance issues, is the need to continuously monitor and improve. If you are not auditing, testing, re-educating and training staff on the hospital compliance program, it can be easy to miss and/or fail to uncover a patent defect or blatant case of fraud. Federal regulators, such as the OIG, CMS and DOJ, do not look positively at all on the failure to discover, remedy and/or avoid Stark Law, fraud and abuse and related billing issues.
Compliance is everyone’s job. From the employee, to management to the CEO. Compliance departments are typically the department that is responsible for ensuring the hospital is continuously compliant. In truth, it takes everyone to do it and to do it right. If employees or patients do not see it, feel it and believe it is core to the delivery of quality care, your hospital increases its chances for a whistleblower claim and/or lawsuit.
So, an effective compliance department will continuously need to review, audit, train and conduct investigations into allegations or even the appearance of impropriety or fraud. If you believe that just having policies and procedures in a big and impressive looking notebook on your shelf will accomplish this, you should re-think your compliance program.
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You might also enjoy:
OIG compliance program guidance for hospitals
Healthcare Compliance: Applying Lessons from Kindergarten
Things you didn’t Know about Effective HR Compliance Departments
The Top Healthcare Compliance Software Tools You Should be Using
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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