Corporate Compliance

Tip: What to include in compliance reports

Compliance Monitor, June 17, 2009

The OIG believes an ongoing evaluation process is critical to a successful compliance program. An effective program should incorporate thorough monitoring of compliance implementation and regular compliance program reporting to senior or corporate officers. The OIG recommends these reviews include but not be limited to the following: 
  1. Focus on all programs or divisions, including external relationships with third-party contractors, specifically those with substantive exposure to government enforcement actions
  2. Be designed to address compliance with laws governing kickback arrangements, coding, claim development and submission, reimbursement, cost reporting, and marketing
  3. Address compliance with specific regulations, rules and policies
  4. Include monitoring techniques such as sampling protocols that create a baseline audit of items and services, with provisions to identify and act on significant variations from the baseline
  5. Include periodic reviews to determine if the compliance program’s elements have been satisfied (e.g., initial training, ongoing education, disciplinary actions, etc.)
  6. Include on-site visits, interviews with key people in management, operations, and coding
  7. Use employee surveys designed to solicit impressions of a broad cross-section of staff members
  8. Review medical/financial records and other source documents that support claims for reimbursement
  9. Engage in trend analyses/longitudinal studies that seek deviations from established patterns 
This tip was adapted from the Healthcare Compliance professional’s Guide to Policies and Procedures. For more information on this book or to order your copy visit the HCMarketplace. For more information about effective compliance training programs, join HCPro in a live 90-minute audio conference, Measuring Compliance Training Effectiveness: Tools and Tips to Prove Your Program Works on Friday, June 19, at 1 p.m. (Eastern).

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