Corporate Compliance

Tip: Assessing internal disciplinary effectiveness

Healthcare Auditing Weekly, January 6, 2009

The OIG’s Supplemental Guidance recommends that hospitals consider the following questions when assessing the effectiveness of internal disciplinary efforts:
  • Are disciplinary standards well-publicized and readily available to all hospital personnel?
  • Are disciplinary standards enforced consistently across the organization?
  • Is each instance involving the enforcement of disciplinary standards thoroughly documented?
  • Are employees, contractors, and medical and clinical staff members checked routinely against government sanctions lists, including the OIG’s list of Excluded Individuals/Entities and the General Services Administration’s Excluded Parties Listing System?
This tip was adapted from the Compliance Program Effectiveness Handbook. For more information about the book or to order your copy, click here.


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