Chapter 3: Running an Effective Compliance Program

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Introduction to Running an Effective Compliance Program

Establishing and running a compliance program requires a healthcare organization to take a systematic approach to addressing compliance risk areas, carefully adhere to government guidelines, and involve the entire organization. Everyone from leadership to coding staff needs to understand and value the importance of the compliance program for it to be effective in reducing compliance risks. Fully understanding the risks facing an organization is imperative to forming the program’s foundation. Every organization needs a program that not only exists, but is also effective in the eyes of government regulators and enforcers.

This chapter covers different aspects of running an effective compliance program. This includes who needs to be involved in running the program and how—from the board to management and the chief compliance officer (CCO)—and why having relationships with core departments is critical to the program’s success. What should be in the board bylaws and charter? What should Compliance report to the board? And what is the board’s accountability if an issue goes undetected?

Receiving funding, hiring staff, and conducting an organizational compliance assessment are some additional foundational aspects of setting up a program detailed in this chapter. Important documentation is discussed as well, such as writing a code of conduct and creating policies and procedures. The risk assessment article describes how compliance can identify and rank the most important risks facing an organization. Educating staff and leadership and communicating compliance program initiatives and policies are also elemental program areas, and this chapter is filled with practical ideas and tools for conducting training sessions to build awareness of a program. Reporting mechanisms are another hallmark of a compliance program, and discussed in this chapter are various options for responding to reports, along with adequate documentation.

Understanding these foundational aspects of running an effective compliance program is more important than ever, as regulators increasingly monitor healthcare fraud and abuse. This chapter will give compliance professionals the tools and information needed to help their organizations manage risks, prevent investigations, and keep patient care at the core of their organization’s focus.

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