Corporate Compliance

Tip: Create open lines of communication

Compliance Monitor, October 1, 2008

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Free dialogue allows organizations to identify and respond to problems quickly and easily—before concerns become lawsuits. The structures and processes put in place by the compliance team should make reporting compliance concerns easy for employees, and individuals must feel comfortable reporting errors directly to the hospital.
 
The ability to report compliance issues in a confidential manner, and without fear of retaliation, is one of the OIG requirements for an effective compliance plan. Various compliance guidelines and corporate integrity agreements, which are negotiated as part of the settlement of false claims cases, reflect this importance.
 
The federal sentencing guidelines  allow a reduction in sentencing for defendants with an effective compliance plan. Such sentence reductions apply primarily to organizations that allow for anonymity or confidentiality in reporting purported fraud. Under these programs, the organization’s employees and agents may report or seek guidance regarding potential or actual criminal conduct without fear of retaliation.
 
Entities should thus establish procedures, such as hotlines, through which employees anonymously can report fraud and abuse. The compliance team must investigate each report thoroughly.
 
This tip was adapted from the Healthcare Compliance Professional’s Guide to The False Claims Act. To find out more about this book or to order your copy visit the HCMarketplace



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