SCCE Compliance 101, Second Edition

  1. Introduction: What's in a Name?

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    You may have noticed that some organizations have compliance programs, others have integrity or ethics programs. They are often considered synonymous, but a subtle distinction can be made between the two terms. It is generally thought that the title “compliance program” implies a primary concern with following rules and regulations, whereas the title “integrity or ethics program” puts the emphasis on values and doing the right thing. There may be differences in approach and subtleties of content, but there are basic elements common to both compliance and integrity/ethics programs. Those common elements, whatever the title of the program, are the...

  2. Appendix A.4: Sample Compliance Officer Job Description

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    The compliance officer provides direction and oversight of the compliance program. The compliance officer is responsible for identifying and assessing areas of compliance risk; communicating the importance of the compliance program to the executive management and the board of directors; preparing and distributing the written code of conduct setting forth the ethical principles and policies which are the basis of the compliance program; developing and implementing education programs addressing compliance and the code of conduct; implementing a retaliation-free internal reporting process, including an anonymous telephone reporting system; and collaborating with executive management to effectively incorporate the compliance program within system...

  3. Appendix A.5: Sample Audit Review Form

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    To be completed for a compliance program audit, either routine or random...

  4. Appendix A.6: Sample Confidentiality Statement

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    I understand and agree that, in connection with the performance of my duties as a member of the compliance oversight committee, I will be engaged in activities of a confidential nature, including but not limited to, participating in reviews and evaluations of internal examinations, evaluations, and self-evaluations of the policies, practices, and procedures of this organization. I further understand that, in this capacity, I will be expected to receive and/or to become privy to information of a confidential nature, including but not limited to, financial statements, trade-secrets, strategic plans, contracts with private parties, and other documents and statistics which go...

  5. Appendix A.7: Sample Complaint Information Sheet

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    Questions and Concerns Call Log Sheet...

  6. Appendix A.8: Sample Compliance Issue Follow-Up Form

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    (Optional: Can be used with the “Sample Complaint Information Sheet—Questions and Concerns Call Log Sheet”)...

  7. Appendix A.9: Audit Review Plan Templates

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    * Audit required by XX regulatory, accreditation or other agency...

  8. Appendix A.10: Sample Board of Directors Resolution

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    Office of the Secretary and Chief of Staff...

  9. Appendix B: Code of Ethics for Compliance and Ethics Professionals

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    Compliance and ethics programs serve a critical role in helping to prevent and detect misconduct at and by organizations and to promote ethical business environments. The development and rigorous implementation of effective compliance and ethics programs protects investors, consumers, the business community and the public at large. Compliance and ethics professionals (CEPs) understand that the services we provide require the highest standards of professionalism, integrity and competence. The following Code of Ethics expresses the profession’s recognition of its responsibilities to the general public, to employers and clients, and to the profession. The Code of Ethics has been adopted by the...

  10. Glossary of Compliance Terms

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    Anti-Kickback Law: Prohibits the solicitation, receiving, offering, or paying of any remuneration directly or indirectly in cash or in kind in exchange...

  11. About the Authors

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    Debbie Troklus, CCEP-F,CCEP-I, CHC-F, CHRC, CHPC,is Managing Director for Aegis Compliance and Ethics Center, where she advises clients on a wide variety of compliance related topics including compliance program implementation, compliance program effectiveness reviews, coding and billing, audit, education development and delivery, investigations, IRO services and interim and/or outsourced compliance work. She currently serves on the board of the Health Care Compliance Association and was President in 2000. She also serves on the advisory board of the Society of Corporate Compliance and Ethics and is the current president for the Compliance Certification Board...

  12. 1 What Is a Compliance Program?

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    There are many definitions of a compliance program. On a very basic level it is about education, prevention, detection, collaboration, and enforcement. It is a system of processes, policies and procedures, and controls that are developed to ensure compliance with all applicable rules, regulations, contracts and policies governing the actions of the organization. A compliance program is not merely a piece of paper or a binder on a shelf; it is not a quick fix to the latest hot problem; it is not a collection of hollow words. A compliance program—an effective compliance program—must be a living, ongoing process that...

  13. 2 The Seven Essential Elements

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    The first of the basic compliance elements in industry guidance recommends that the organization establish standards and procedures to prevent and detect criminal conduct.The standards or code of conduct and the policies and procedures become the foundational tools with which you can build your compliance program...

  14. 3 Organizational Steps

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    Compliance begins with the top tier of the organization. Support from the top is very important; there can be no program at all, much less an effective one, without the vision and guidance of the board. It is the board that officially recognizes the need for a compliance program and authorizes its launch and implementation, including the hiring of a compliance officer. The first step toward implementation of a compliance program is management’s communication of their commitment. A resolution or memo from the board stating its unequivocal support for the program is a strong beginning. The source of such a...

  15. 4 Tailoring Your Compliance Program

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    The compliance program must be tailored to fit your organization. There is not a “one size fits all” program. As we have discussed, you need commitment from the top supporting your program, financial support including necessary staffing, and a continual assessment of your program. Once you understand the organization’s needs, then fit your plan to the organization. The code of conduct should be the focal point of your program...

  16. Epilogue

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    As you know, better than most, compliance professionals must deal with complex and cumbersome laws and regulations on a daily basis. But industry laws and regulations are not new. Today, more so than in the past, we are approaching compliance in a formal, systematic way...

  17. Appendix A.1: Sample Letter to Vendors

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    Dear Vendor Colleague:...

  18. Appendix A.2: Sample Non-Retaliation/Non-Retribution Policy

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

  19. Appendix A.3: Sample Search Warrant Response Policy

    SCCE Compliance 101, Second Edition  | Authors: Debbie Troklus, Sheryl Vacca  | January 2015 

    XXX recognizes that the government has increased its scrutiny of organizations by deliberately focusing on practices it considers fraudulent and abusive. It has a number of techniques at its disposal to use when investigating suspected fraudulent activity. Those techniques include grand jury subpoenas, civil investigative demands, civil subpoenas, and search warrants. Among these techniques, the use of search warrants has grown in popularity among government investigators for a variety of reasons, thus increasing the likelihood that the organization, its Office of Compliance, or other officers may be served with a search warrant. People have the right to be secure against...