An "effective" compliance program as defined by the Office of Inspector General (OIG) is scalable to your practice. There is no one-size-fits-all. OIG Compliance should be "woven into the fabric of routine operations." This means that compliance is incorporated into daily operations and is demonstrated by all members of the organization from the top down. It should come easily to you and your team with clear guidelines in place that aim to preventing potentially fraudulent activity.

Based on the US Sentencing Guidelines, there can be up to a 95% reduction of fines if an "effective" program was in place prior to the detected misconduct.

1.

Standards & Conduct
  • Assess risk areas and implement policies and procedures to reduce risks

  • Obtain commitment from each Board member and/or owner

  • Create an organizational Compliance Culture (Code of Conduct)

2.

Oversight
  • Designate Compliance Officer and Committee with roles and responsibilities

  • Provide clear lines of communication to Board and defined reports

  • Present compliance activity reports to Board (Compliance Committee Meeting)

3.

Education & Training
  • Develop training and education specific to the job tasks

  • Use real cases specific to the organization

  • Utilize HCP resources and HEAT videos

4.

Reporting
  • Develop effective communication lines

  • Use anonymous reporting (hotline 24/7) (available through HCP)

  • Implement 'no retaliation' policy for good faith reporting

5.

Monitoring & Auditing
  • Monitoring should be a part of daily operations

  • Drill down into problem areas

  • Schedule follow-up audits with external auditors (CRA/Audits)

6.

Enforcement & Discipline
  • Implement a Discipline Policy for noncompliance

  • Demonstrate level playing field with discipline enforcement

7.

Response & Prevention
  • Respond promptly to detected offenses

  • Take action on all reports

  • Follow-up with appropriate communications

  • Implement corrective actions / monitor improvements

OIG COMPLIANCE PROGRAM

THERE IS NO ONE-SIZE FITS ALL.

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