Corporate Compliance

Auditing against the OIG’s Compliance Program Guidance for Hospitals

Healthcare Auditing Weekly, April 11, 2006

Today, we'll continue our discussion of auditing against the OIG's Compliance Program Guidance for Hospitals with guidelines for auditing to verify that your facility ensures compliance standards through an effective new employee policy. When reviewing your hospital's new employee policy, determine whether the following provisions are in place:

  • The hospital conducts a reasonable background investigation, including reference checks, on every new employee who has authority to make decisions involving compliance with the law or compliance oversight

  • Employment applications require applicants to disclose any criminal conviction or exclusion action

  • Hospital policies prohibit hiring an individual who recently has been convicted of a healthcare-related criminal offense or who is listed as debarred, excluded, or otherwise ineligible for participation in government healthcare programs

  • The hospital terminates employment or contracts with current employees or independent contractors who are convicted, debarred, or excluded from government healthcare programs

      The above tip is an excerpt from the book "Hospital Auditing and Monitoring: Sample Programs for Key Risk Areas." Copyright 2004 by HCPro, Inc. This book is a step-by-step, practical manual that offers sample audit programs for the most troublesome areas that a hospital must audit. The binder and CD-ROM are filled with actual audit programs used by auditors and compliance officers in the field. Click here for more information or to order your copy today.

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