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Using Corporate Compliance and Ethics Week to brand a compliance program

Kerri Ervin ( is Corporate Compliance Officer at Avow, Inc. in Naples, FL.

Clinical staff members at hospice organizations often choose their line of work to make a difference in the lives of others. Although their primary focus is always on providing patients and their families with the best possible care, they also acknowledge that healthcare is changing and understand that there is more regulatory scrutiny every day. Hospice clinical staff members look for ways to meet the needs of those they serve while remaining compliant, because compliant practice helps to ensure that the organization will continue to fulfill its purpose of bringing comfort, peace, and calm to those in need. My job as a hospice compliance professional is to help our hospice care clinical staff provide compliant, high-quality care. I work to make the connection between compliance and practice easier and more streamlined so that compliance is just a part of everyday thinking and practice.

Hospice is an area of healthcare under intense scrutiny. Not unlike other areas of healthcare, hospice programs operate under a significant number of rules and regulations. The Centers for Medicare & Medicaid Services (CMS), the Office for Civil Rights (OCR), state survey agencies, and accrediting bodies provide oversight. Hospice, unlike some other areas of healthcare, is not required to have a compliance program. However, the Health and Human Services Office of Inspector General (OIG) released compliance program guidance for hospices in 1999, and a hospice would have a very difficult time explaining the lack of a formal compliance program today.