December 7, 2021

Volume XI, Number 341

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December 06, 2021

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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.

©2021 von Briesen & Roper, s.cNational Law Review, Volume II, Number 26
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About this Author

von Briesen & Roper’s Health Law Section provides comprehensive legal services to the health care industry nationwide as both general counsel and special project counsel. Our clients include integrated delivery systems, academic medical centers, community hospitals, Catholic-sponsored hospitals, rural and critical access hospitals, imaging centers, physicians and multi-specialty clinics, specialty hospitals, ancillary suppliers, home health agencies, nursing homes, hospices, assisted living facilities, mental health and AODA facilities, DME suppliers, laboratories,...

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