Effective Compliance in Small Organizations · 3/4/2011 11 Federal Sentencing Guidelines Ethical...
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3/4/2011 1 Effective Compliance in Small Organizations Faith Jones, MSN, RN, NEA-BC Kara Beech, BS, CHC Objectives • Analyze current position functions to imbed compliance into the foundation of your organization • Enhance relationships throughout the organization that will increase your compliance foundation • Utilize the network of knowledge to assign the various hats within your organization
Transcript of Effective Compliance in Small Organizations · 3/4/2011 11 Federal Sentencing Guidelines Ethical...
3/4/2011
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Effective Compliance
in Small OrganizationsFaith Jones, MSN, RN, NEA-BC
Kara Beech, BS, CHC
Objectives
• Analyze current position functions to imbed
compliance into the foundation of your
organization
• Enhance relationships throughout the
organization that will increase your
compliance foundation
• Utilize the network of knowledge to assign the
various hats within your organization
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What is Compliance?
Who are you accountable to?
What regulations do you follow?
Group Exercise
Source: Hospitals and Health Networks Magazine, April 2001
Your
Organization
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Overwhelmed Yet?
Can your compliance program be
everything to everybody?
Rest assured, you are already doing more
than you think.
Where do you Start?
• Visualize building your program from the
bottom up.
• And the foundation is……..
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Foundational Building Blocks
• Federal Sentencing Guidelines
– Standards of Conduct/Policies & Procedures
– Compliance Officer and Compliance Committee
– Education
– Monitoring and Auditing
– Reporting and Investigation
– Enforcement and Discipline
– Response and Prevention
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Ethical Culture
Do the right thing,
for the right reasons,
in the right way.
Building your Program
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Policy and procedure
development is the
framework that builds on
your ethical culture.
Building your Program
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Building your Program
Talent Acquisition
It’s an in-house search!
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Talent Search
• Compliance Officer
– Access to the Board of Directors
– Report to Senior Level Executive (CEO)
• Role
– You may need to wear several hats
– You’re the Mayor, not the Sheriff
Compliance
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Talent Search
• Compliance Committee
– Not a repository of reports, but a work group of
information sharing
– A working committee made up of personnel with
varied expertise
• Commonly known as “Other duty as assigned”
• Align innate abilities with specific compliance functions
• Compliance is everyone’s job Compliance
Committee
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Officer
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Seeking Experts
• Education background
• Past work experience
• Communication/education/training skills
• Personality types
• Life long learners/self starters
• Problems solvers
Talent Search Sources
• EMTALA Expert
– Trauma Coordinator, OB Nurse, Triage Specialist, Admission Coordinator, etc.
• HIPAA Expert
– Medical Records specialist, Receptionist/PBX Operator, IT specialist, etc.
• Billing & Coding Experts
– Medicare Biller, Collector, Coder, Utilization Review, Case Management, etc.
• Think beyond the management team
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Talent Search Sources
What experts would you need for a well
rounded compliance program?
Group Exercise
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Educating the Experts
• Become a member of HCCA
• Identify a researcher
• List Serves (HIPAA Weekly Advisor, Compliance
Update, TWCC, etc.)
• Websites (OIG, CMS, HCCA, HcPro, etc)
• Networking
– Look around the room and use your break
time wisely
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Monitoring and Auditing
• You can’t do everything
• You will be amazed at what you can build one
piece at a time
• Take credit for what you do
• Reinforce your accomplishments
to sustain your results.
• M&A protects your program.
Approach to New Regulations
• Researching and being aware of the trends and conversations prior to it becoming a law/rule.
• How did you find out about it?
• Who is your subject matter expert?
• Is anyone else doing anything similar on the subject? (Do not duplicate work!)
• Develop a policy and procedure
• Education staff
• Monitor and audit the process
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Program Structure
A structure that will withstand the implementation of new regulations, as well
as investigating, disciplining, and reporting issues of non-compliance.
Resources American Hospital Association www.aha-solutions.org
Compliance 360 www.compliance360.com
HCCA http://www.hcca-info.org
HCPro www.hcpro.com
HHS OIG www.oig.hhs.gov
Meade & Roach www.meaderoach.com
SCCE http://corporatecompliance.org
The Healthcare Compliance Blog www.thecomplianceblog.com
A Compliance & Ethics Program on a Dollar a Day: How Small Companies Can Have Effective Programs by Joseph E. Murphy, CCEP
Compliance 101 by Debbie Troklus, CHC, and Greg Warner, CHC
The Health Care Compliance Professionals Manual by CCH & HCCA
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Contact Information
Faith Jones, MSN, RN, NEA-BC
Kara Beech, BS, CHC
