TCG wants to help your organization set the standard for corporate compliance success! Our Corporate Compliance Tip #2: Set the Standard focuses on the OIG’s Fundamental Elements three, four and five incorporated in our Corporate Compliance Programs Essentials guides. The guides educate home care organizations using the OIG Seven Fundamental Elements as outlined in the Federal Register.
When implementing a Corporate Compliance Program it is important to provide effective training and education. When it comes to education, all personnel need information about the compliance aspects of their specific duties and responsibilities. This includes everyone in the organization, from executives to staff to all other stakeholders. Training should be required at orientation and on an annual basis thereafter. Compliance trained instructors are integral in order to consistently train everyone involved. When developing training sessions, remember to incorporate the following but not be limited to:
• General prohibitions on paying or receiving remuneration to induce referrals
• The physician self-referral law
• Improper alterations to clinical and billing records
• Providing home health/hospice services with proper authorization
• Proper documentation of services rendered, including the correct application of official ICD and CPT coding rules and guidelines
• Patient rights and patient education
• Compliance with Medicare conditions of participation
• Duty to report suspicions of non-compliance
• Marketing guidelines
Another important element of a Corporate Compliance Program is to develop effective lines of communication. Communication allows the organization to gather the force to propel itself to the center of the compliance target. In order to continue success throughout the organization it is important to develop effective lines of communication. Be sure to allow time for questions and discussions while keeping a respectful and meaningful exchange. This can be accomplished by using several different means of communication, for example:
• Emails
• Toll-free hotline
• Newsletters
• Website
• Faxes
• Survey
• Bulletin Boards
Lastly, always make sure to enforce standards through well-publicized disciplinary guidelines. Remember when implementing your program, problems arise and it is important to adhere to established policies and be prepared to react to any issues that may occur. Disciplinary guidelines must be in place to counteract any setbacks because being inconsistent is harmful for an organization. If an incident occurs here is a good standard to follow for typical steps taken:
1. Letter of Reprimand
2. Probation
3. Monetary Penalties
4. Pre-dismissal
For detailed information, graphs and samples, our Corporate Compliance Program Essentials guide is available at store.corridorgroup.com.
