Corporate Compliance

Tip: What to do if there is a noncompliance problem

Healthcare Auditing Weekly, April 7, 2009

Deciding what to do when there’s an instance of wrongdoing may be the hardest part of an auditor’s or compliance officer’s job. There are some commonly used guidelines for collecting and handling reports of noncompliance. The decisions you make in regard to locating and handling problems appropriately can fend off future government investigations and lawsuits.

The following are suggestions for handling noncompliance issues:

  1. Report problems to the appropriate place. When you uncover an instance of noncompliance, consider the best place to report the problem, such as management.
  2. Know and follow your organizations protocol. In most cases, auditors report compliance problems to the hospital’s compliance officer. Professional standards may also require you to go to the company’s board or governing entity.
  3. Get professional assistance. If a situation calls for self-disclosure, providers should rely on counsel—either in-house or outsourced—to assist with the process.
  4. Advocate for you position. If you are a compliance officer or an auditor trying to convince the board of director’s to authorize an investigation, know that your presentation style could affect their decision. Consider:
  • Providing copies of the relevant law to emphasize the importance of the board’s decision
  • Bringing in an outside consultant to review the matter and present your case
  • Highlighting recent government actions in well-publicized cases of fraud and abuse
  • Presenting the pros of self-disclosure

This tip was adapted from The Healthcare Auditor’s Handbook. For more information about the book or to order your copy, visit the HCMarketplace.

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