1 / 11

Developing and Implementing an Effective Compliance Program

Developing and Implementing an Effective Compliance Program. Mary Sacilotto,BA,CHC Chief Compliance Officer Alliance, Inc. Establishing a Commitment to Compliance. Board of Directors President/CEO Chief Compliance Officer Essential Compliance Staff Compliance Committees Legal Counsel.

jayden
Télécharger la présentation

Developing and Implementing an Effective Compliance Program

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. Developing and Implementing an Effective Compliance Program Mary Sacilotto,BA,CHC Chief Compliance Officer Alliance, Inc.

  2. Establishing a Commitment to Compliance • Board of Directors • President/CEO • Chief Compliance Officer • Essential Compliance Staff • Compliance Committees • Legal Counsel

  3. Hiring a Compliance Officer • Experienced in management • Trusted and respected • Effective communication skills • Strong leadership skills • Self-confidence • Stamina • Must have direct and regular contact with the Board of Directors

  4. Compliance Guidance • Health Care Compliance Association (HCCA) (www.hcca-info.org) • U.S. Federal Sentencing Guidelines • U.S. Department of Health and Human Services (HHS) • Office of the Inspector General (http://oig.hhs.gov/index.html) • Centers for Medicare and Medicaid (http://www.cms.hhs.gov)

  5. Seven Elements of an Effective Compliance Program • Written Standards of Conduct • Designate a Chief Compliance Officer & other appropriate bodies – Compliance Committees • Effective Education & Training • Audits and Monitoring • Reporting and Investigating • Appropriate Disciplinary Mechanisms • Response & Prevention

  6. Project Management Plan • Create standards for compliance (conduct, conflict of interest, fraud & abuse, disclosure) • Establish a formal relationship for legal compliance referrals • Implement an anonymous hotline as a reporting mechanism • Implement compliance complaint logs • Develop a compliance program training that outlines organizational culture of corporate ethics • Develop educational presentations programs for Board • Establish Compliance Committees – Board and Internal • Implement an ongoing audit schedule • Expedite investigations and remedy alleged misconduct • Review current policies & procedures for compliance • Measure effectiveness of program ( surveys, focus groups, trend analysis)

  7. Compliance Work Plan • Develop an annual work plan • OIG work plan • Semi-annual risks assessments • Audits (internal & external) • Regulatory requirements • Seven elements – education, training

  8. Establish Compliance Policies • Code of Conduct • Conflict of Interest Policy • Non-Retaliation Policy • Whistleblower Policy • Anonymous Reporting Tool • False Claims Act

  9. Championing Compliance • Meet with Program Directors/Managers • Facilitate Risk Assessments • Conduct Mandatory Compliance Training • Attend Staff Meetings • Conduct Focus Groups • Be visible and keep an open door policy • Establish a rapport • Be flexible and keep an open mind

  10. Sustaining a Compliance Program • Considered a work in progress • Constantly changes to adapt to the needs of the company • Develop an Annual Work Plan and assess regularly (approved by Board of Directors) • Remain on the cutting edge by taking advantage of conferences and training opportunities • Establish credibility

  11. Questions?

More Related