Compliance • Audits/Analysis • Reimbursement/Regulatory • Education/Efficiency
As a continuation of the 7-Post Blog Series on Compliance, today we will explore #6 Responsibility/Oversight/ Committee.
- Policies and Procedures
- Reporting and Investigating
- Education and Training
- Prevention and Response
- Auditing and Monitoring
- Responsibility and Oversight Committee
- Enforcement, Discipline and Incentives
Responsibility and Oversight Committee
Compliance and Ethics Programs are implemented to prevent and detect violations of the law, promote a principled culture, message the top down expectation or moral behaviors and intolerance of corrupt actions, and to educate staff on how to recognize threats to the organization. These goals require Responsibility and an Oversight Committee in order to succeed.
The ultimate Responsibility of an effective Compliance Program falls on the Board of Directors. Leadership and Management are accountable for the success or failure within the organization. However, there needs to be a designated Compliance Officer with the proper credentials, resources, authority and training to guide the organization in its daily and annual plan for Compliance.
The Compliance Officer must have a direct line to the highest level of management or ownership. If not, the structure lacks the components and optics to safeguard against wrong doing. In addition, an improper structure is a reflection of a poor understanding of the government’s expectation. This in itself leads further scrutiny and less success during an investigation.
For Example: If the Compliance Officer reports to the Administrator of the Skilled Nursing Facility and there is an owner above the Administrator, this structure lacks the internal controls and oversight of the Administrator’s actions. In fact, this mere flaw in the structure gives the investigator great pause and reason to question the overall program integrity of the facility.
Tip: Assess the reporting structure of the Compliance Officer within your organization.
The Compliance Officer reports all compliance activity to the board of directors and the compliance oversight committee. In addition, the Compliance Officer facilitates the Annual Compliance Plan, Risk Assessments and Educational aspects necessary for integration of the compliance program into the operations.
The overarching goal of oversight is to establish systems and structures that inherently trigger awareness of risks.
A Compliance Oversight Committee is recommended by the Officer of Inspector General (OIG) for the primary purpose to oversee the implementation and operation of the program. Tasks include the report reviews, statistical trend analysis and discussion of the Compliance Officer recommendations. Monthly meetings are highly recommended for new programs.
The committee structure, composition, attendance, documentation, reporting, goals and functions are all elements that require transparent delineation and ongoing review for an effective functioning committee.
Harmony Healthcare International (HHI) offers a unique approach to Auditing and Monitoring. Our program combines QAPI, Compliance and Medical Record Review into a user-friendly, process refinement methodology. Please call us to hear more about our monthly service plans (Platinum, Gold and Silver) and knowledge center (HarmonyHelp).
As always, I hope this helps with your Quest for Compliance!!
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