Corporate Compliance

Tip: Requiring Training

Compliance Monitor, October 3, 2007

The OIG recommends that hospitals require attendance and participation in training programs. The OIG advises that such training should be a factor in the annual evaluation of each employee. Failure to comply with training requirements should result in disciplinary action, including possible termination, when such failure is serious.

Where feasible, the OIG believes that hospitals should offer outside contractors, including physicians, the opportunity to participate in, or develop their own, compliance training programs, which compliment the hospital's standards of conduct, compliance requirements, and other rules and regulations. A Stark Law exception allows for hospitals to provide free compliance training without it being considered to be illegal remuneration.

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