Healthcare Compliance Annual Review Suggestions
To meet the requirements of increasingly complex healthcare regulations, hospitals and other healthcare entities must ensure the effectiveness of their compliance programs. Before starting your compliance program review, start by becoming familiar with Office of Inspector General (OIG) regulations. Next, it’s time to look at your compliance program. How well does your organization meet these requirements, and how do you measure its effectiveness?
In order to help healthcare entities stay in compliance, the Office of Inspector General (OIG) has provided compliance guidance documents. These documents provide guidance on compliance issues to watch for in your segment of the industry (different rules govern nursing homes, hospices, suppliers, etc.). These OIG audit reviews may also be helpful.
When you’re conducting your annual compliance review, you may also benefit from general suggestions for areas to review. These suggestions are not intended to be an exhaustive or comprehensive list, but they can help you develop your own checklist for your compliance program review to meet the needs of your practice. For more detailed compliance program effectiveness measurement ideas, visit OIG’s Resource Guide. If your organization is just starting a compliance program or reviewing it for the first time, OIG’s Compliance Resource Portal can provide additional guidance.
What Should Your Compliance Review Cover?
At a minimum, your compliance annual review should examine the following seven areas:
- Policies and Procedures: Make sure that everyone has access to the policies and procedures and understands them clearly. Determine who has responsibility and accountability for each policy. Measure your policies against industry standards and regulations to ensure compliance. Verify that your employees understand your policies and procedures, including your compliance plan.
- Administration: Ensure the compliance program has adequate resources to fulfill its responsibilities and that it is supported by administration, the board, and staff. Survey the staff to find out the impact of the compliance program on your organization’s culture. Evaluate your compliance plan’s effectiveness internally and externally. Check if the compliance program’s accountability reaches all aspects of the organization, including incentives, evaluations, risk assessments, and disciplinary action.
- Physicians and Employees: Verify accountability for screening of physicians and other employees, including contractors. Check policies for exclusion screening against OIG guidelines. Ensure your employees and vendors understand and follow your compliance policies. Include employees’ compliance responsibilities in job descriptions, interviews, employee education, performance evaluations, and exit interviews.
- Audits: Review your reporting system documents, especially the following: benchmarking reports, report tracking, response time, investigation reports, completion notes, disciplinary reports. Make sure any compliance program involvement with any incidents is documented and complete. Check documents for accessibility and survey employee understanding of compliance documentation. Review risk assessment documentation. Review your work process, work plan (including the hiring of outside/legal experts), corrective action plan, and vendor oversight plan. Verify non-retaliation for reporting compliance issues.
- Discipline: Verify that your disciplinary policies are clear, consistently applied and that employees understand them. Review the documentation of your compliance policy for accessibility, transparency, clarity, and availability.
- Investigation: Review your policies and procedures concerning compliance investigations. Verify that they include non-retaliation for reporting compliance issues. Make sure your investigation records are thorough and consistent and that your investigators are trained, competent, and impartial. Track your investigations, watching for trends. Verify that investigational outcomes are used for organizational learning and that escalations are handled appropriately.
- Compliance Training: Verify that training programs are comprehensive and attended by high-risk personnel. Training completion should be documented. Include everyone in compliance training, including physicians, employees, board members, vendors, and volunteers. Survey trainees to evaluate the success and relevance of compliance training.
Support for Your Compliance Program
Healthcare rules and regulations concerning healthcare law change quickly, so a compliance annual review is the best way to ensure your practice follows OIG regulations. Your compliance plan review matters. Reviewing your healthcare compliance plan, and updating or changing it as needed, protects your healthcare entity and your patients.
Stay compliant with Verisys. We will keep your organization safe, secure, and fully compliant while meeting all federal and state regulatory standards. Verisys provides turn-key provider screening, identity and licensure verification, credentialing, and monitoring powered by the most comprehensive data in the healthcare industry. Our credentialing experts utilize real-time provider exclusion data, which allows your organization to operate with full transparency within your compliance program.
|Written by Juliette Willard
Healthcare Communications Specialist
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