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Evaluate your compliance culture

HIM Connection, November 28, 2003

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Dear Colleagues:

Organizations are training employees and physicians on correct documentation and coding to ensure compliance, but it's not always easy to determine how entrenched in your facility's culture the compliance program is.

Try a compliance program evaluation, Darrell Contreras suggested at the Health Care Compliance Association's Annual Compliance Institute.

Ask the following questions:

Compliance officer

• Do employees know who the compliance officer is and how to contact him or her?

Code of conduct and policies and procedures

• Do employees know about the code of conduct?
• Do employees know where to find of policies and procedures, and do they use them for guidance?

Training programs

• Are problems addressed in training still recurring repeatedly?
• Does post-testing indicate that your employees understand compliance?

Hotline

• Do employees know about the hotline?
• Are they willing to use it?

Non-retaliation policy

• Do employees know about this policy?
• More importantly, do they believe it? If not, why not?

Repayments

• Is documentation of overpayments available?
• Is there a policy for making repayments or voluntary disclosures?

This week's HIM Connection was adapted from the special report, "An inside look at compliance auditing and monitoring: Integrating government standards." Click here for more information or to order. Go to http://www.himinfo.com to participate in our instant survey on membership in HIM and coding organizations. See the Editor's Choice section for a special HIPAA training handbook just for HIM staff.

Sincerely,

Lauren McLeod
Senior Managing Editor
lmcleod@hcpro.com

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