By Michael Rosen, Esq.
For some January is a time to slow down, breathe and plan for next year. Ever ask yourself if there is a busy or slow time for compliance? Is it even possible to take your eye off the ball when it comes to compliance?
Compliance is 24/7/365. Compliance does not take a break and an effective compliance program is top of mind all the time – and not just for healthcare compliance officers. The most effective and best practice organizations have a defined compliance program that is embedded throughout the entire organization and even championed from the C-Suite down the line.
So, can there be a slow time for compliance? No. But, this is the time of year that healthcare compliance officers and their teams should do the following:
- Review their performance in 2015 and determine gaps or areas for improvement.
- Set a plan for enhancement and continued training for 2016.
- Determine if audits were conducted timely, effectively and were reported to management and the Board of Directors.
- Conduct Benchmark comparisons to determine if and how the organization was compliant. If areas of non-compliance are identified, seek legal advise and consult with management about possible self-disclosure.
- Share and learn best practice from your counter-parts in the industry. In health care, there is a community of sharing and collegiality unlike other industries. Take advantage of and join peer networks for 2016.
Benefits of Compliance Review, Pivoting and Transparency:
First, it’s about developing a culture of compliance and getting buy-in from all departments and leaders in the organization. Best practice healthcare organizations have seen the light in this area and make compliance part of their every day fiber. A plan is just a plan if it is not shared, taught and made a part of the culture.
Second, no one is perfect. Even those who are good at compliance. So, when or if you find areas for improvement, do something meaningful about it and be honest. If a mistake was made, correct it and report it. This will help reduce fines and unnecessary regulatory oversight.
Finally, you are not alone. Lean on and learn from your compliance colleagues. No one likes to see their competitor or colleague suffer at the expense of good and safe health care practices. Join peer groups and be transparent.
Although compliance is never able to truly rest, this is the time to reflect, renew and re-emphasize the importance of compliance in your organization. Remember, people want to do the right thing and to be part of an organization that believes, talks and walks what it espouses. This means compliance should be at the forefront of the culture.
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