“Discipline is the bridge between goals and accomplishment.” Jim Rohn
Not only is it impossible to address every possible violation in disciplinary guidelines, it’s not expected.
OIG Compliance guidance states that “each situation must be considered on a case-by-case basis to determine the appropriate sanction.” Cases of minor misconduct are often best handled informally. Whereas more serious situations, or where an informal approach has been unsuccessful, formal action is appropriate.
Responses to compliance lapses may be in the form of corrective action and/or disciplinary action. When developing your disciplinary program, you may wish to provide for the following range of actions:
- Written Notice of Counseling
- Performance Improvement Plan
- Letter of Reprimand
- Suspension without pay
It may also be necessary to suspend an employee with pay during the course of an investigation if the presence of that employee would hinder the investigation. If this is the case, there is increased urgency in obtaining a resolution quickly, for the benefit of all involved.
Of course, if your organization has a Human Resources Department or General Counsel, you should include them in defining the disciplinary process and in taking action in response to a lapse. Also, as noted elsewhere in TCG Compliance QuickTips©, disciplinary policies should include an appeal process and be well communicated at all levels of the organization.
For additional Resources, check out these websites:
- Progressive Discipline Policy and Procedure – Society for Human Resource Management
- OIG Compliance Program, Guidance for Hospices
- OIG Compliance Program, Guidance for Home Health Agencies
Prepare. Reinforce. Go Further.
TCG Compliance Solutions is ready to assist you implement and enhance effective controls and best practices for seamless compliance.
Contact us for the necessary tools, resources and expertise to reach compliance efficiency.