April 19, 2014

OIG Posts Tips for Implementing an Effective Compliance Program

Yesterday the Office of Inspector General (OIG) added a video to its HEAT training website. The newest video outlines the OIG’s tips for implementing an effective compliance program. The six tips include:

  1. Foster a culture of compliance: Support your compliance program with sufficient resources. A financial commitment to compliance will show the OIG that your organization values integrity.
  2. Functional policies and procedures: Create policies and procedures that are up-to-date, user friendly, and specific to each job function. Include real-life compliance issues faced by your organization.
  3. Training: Offer compliance training often, and make it creative and current.
  4. Promote communication: Make your compliance department visible and approachable, talk about your organization’s non-retaliation policy in staff meetings, and solicit feedback with anonymous online surveys.
  5. Take appropriate corrective action: Develop a system to track and respond quickly and thoroughly, act promptly when potential issues are identified, and document corrective action. Be mindful to avoid conflicts of interest with staff involved in investigations. Track resolution of compliance issues, and familiarize yourself with the OIG self-disclosure protocol.
  6. Audits: Conduct regular audits in risk areas (e.g., coding, contracts, and quality of care) and investigate root causes. Review your compliance plan including whether you are meeting benchmarks and whether corrective action plans are sufficient.

The OIG video is available here.

©2014 von Briesen & Roper, s.c

About the Author

Meghan C. O'Connor, Health Care Attorney, Von Briesen Law Firm

Meghan O’Connor is a member of the Health Care Section and the Government Relations and Regulatory Law Section. She advises clients on a wide range of regulatory compliance, corporate, and transactional matters, including: HIPAA, HITECH, and other federal and state confidentiality laws; provider and vendor contracting; health care reform, Medicare, and Medicaid compliance; patient care and risk management issues; managed care; insurance regulation; and clinical integration and accountable care networks.

Prior to joining von Briesen, Meghan worked for the U.S. Department of...


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