Over the last 15 years, I have seen Compliance grow as a profession as well as a program. The multiple roles I have had in my 30 years in Long Term Care have assisted in the evolution of my becoming a Compliance Professional. I was actually thrilled to hear that establishing a formal and effective Compliance program would be a mandatory requirement for Long Term Care Facilities and a condition of participation in Medicare/Medicaid programs. It makes it easier to implement Compliance related activities and engage the Health Care staff in taking the Compliance program more seriously. It was no longer optional!
Do you wear multiple hats or only serve as a Compliance Officer? It can make a difference in terms of a potential conflict of interest and truly having the time to dedicate to ensuring compliance with the eight program elements. Your Compliance program will always need to be tailored to the uniqueness of your facility taking into account size, resources and culture. As long as you have implemented the eight elements and are in accordance with OIG requirements and the Federal Sentencing Guidelines, your Compliance program will be on the road to success.
The tone at the top is what helps to establish the foundation for your Compliance program. Without the support of Senior Management, implementing and maintaining the program could pose a challenge. It is additionally important to engage employees at all levels in the Compliance process and make them feel that their feedback and participation in the Compliance program is essential. The success or failure of the program can rest with the Compliance Officer who will need to lead the way. The inter-disciplinary Compliance Committee that meets a minimum of quarterly will need to provide the required support for the Compliance Officer. Do you have a committee that expects the Compliance Officer to speak for the entire meeting or do they participate, provide reports and give feedback? A carefully thought out agenda, which outlines specific reporting requirements for Department Heads/Managers will assist in designating responsibility and relieve the Compliance Officer of giving all the updates. Compliance is everyone’s responsibility!
The rewards of managing an effective Compliance program will be reaped when you conduct an annual assessment and identify that you are relatively satisfied with your Compliance achievements for the year or when OMIG performs a Compliance program audit and you receive few insufficiencies.
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