When the OIG released its updated healthcare compliance program guidelines in November, it became clear that if you don’t have a well-designed program, you could be in violation of the regulations.
Your best bet is to familiarize yourself with every detail of the new compliance program guidance so you enter 2024 with your i’s dotted and your t’s crossed.
Start With a Risk Assessment
Performing a risk assessment of your practice will help you understand where your vulnerabilities lie. It will also allow anyone reading your compliance plan to gain a firm grasp of your business from a commercial perspective. They’ll learn how the company has identified, assessed, and defined its risk profile, and the degree to which the program devotes appropriate scrutiny and resources to the spectrum of risks.
This should always be your starting point, since everything after it is based off what you discovered during the risk assessment.
Develop Policies and Procedures
Your practice surely has policies and procedures in place to ensure you stay compliant with the government’s regulations, but it’s essential that you write them down. That way, it will be clear to anyone reviewing your compliance program that you are working to reduce any risks and that you have strict policies in place to follow if a compliance issue is identified.
Strengthen Training and Communication
Even if you have the world’s best policies and procedures in place, if you don’t train the staff on them and communicate changes with your team, your policies mean nothing. Keep records of periodic training sessions and certification for all directors, officers, relevant employees, and agents/business partners (where appropriate).
Maintain a Confidential Reporting Structure and Investigation Process
Employees should be able to anonymously and/or confidentially report allegations of a breach of the company’s code of conduct, company policies, or suspected or actual misconduct. You should also create a workplace atmosphere without fear of retaliation. Put appropriate processes in place for the submission of complaints, and make sure you protect whistleblowers
Manage Third Parties
Your compliance program should extend not just to your team, but also to third-party relationships you have in place, including billing firms, DME providers, satellite offices and other entities.
If you are involved in any mergers or acquisitions, you must make sure they have a compliance program in place and train them on yours when they become part of your organization.
Deal With Misconduct Swiftly
If you do experience a violation of your practice’s compliance program, you should have a remediation program in place and deal with any misconduct immediately. If you have a track record of letting violations slide, then your program really isn’t worth anything at all.
You can get a lot more tips about creating a strong compliance program from healthcare attorney Amanda Waesch, JD during her online training, New 2024 OIG Healthcare Compliance Program, Avoid Audits/Fines. Register today!
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