How to Get Proactive for Your Healthcare Client’s FDR Compliance Requirements

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By Stephanie Jenkins
Chief Compliance Officer of ETHIX360

I’ve been with ETHIX360 as the Chief Compliance Officer for a little over a year and half. During this time, we’ve built an ethics and compliance program that fosters a culture of partnership and integrity. Through the strength of the partnerships, we seek ways to become a better, stronger provider of hotline/ whistleblower, case management platforms. As a First-Tier, Downstream and Related entity (FDR), we take our additional partner responsibilities very seriously.

Organizations in the healthcare sector are responsible for ensuring its FDRs meet the compliance requirements of the Medicare program, and this isn’t an easy undertaking. ETHIX360’s healthcare clients are responsible for their own internal compliance program as well as the programs of their FDR’s. So not only are they managing their own compliance-crazy, they have to keep an eye on their downstream vendors compliance-crazy. And most of them are working with multiple FDR’s.  To that end, anything I can do to make their lives and jobs easier, I’m 100% onboard to do.

One of the first projects I undertook when I join ETHIX360 was to create what I refer to as a “Healthcare Client Welcome Packet.”  I want our healthcare clients to think of me as a resource, a “welcome wagon” team, but instead of gifts and coupons, I give proof wrapped in a nice red virtual bow.  I’m a firm believer in taking a proactive approach to compliance.  Being proactive makes my life easier because I know we are going to pass our audits. It also makes our healthcare partners life easier, because they know that they can count on us.

What does an FDR Compliance Welcome Packet consist of? So glad you asked!

  • Our Employee Universe – A list of all ETHIX360 employees
  • All things training – From copies of the training to the proof they’ve been completed by every employee
  • Copies of all relevant policies and procedures and attestation proof
  • Dates for completed Conflict of Interest forms
  • Evidence of screening for Excluded Individual

The most important piece in my healthcare welcome packet is setting up a relationship based on responsive and open communication.  I recognize that our healthcare clients have unique and specialized regulatory needs.  They are often under a lot of pressure, many times, with deadlines beyond their control.  To that end, all of ETHIX360’s clients have my cell phone number and are encouraged to reach out to me at any time.  I always tell clients that if they’ve been given an insane deadline to provide evidence their FDRs are compliant, reach out to me… if it’s urgent, just say the word and I’m on it.

I think all compliance professionals are fighting for the same cause, but perhaps from slightly different angles.  Ultimately, we want to meet all legal FDR compliance requirement, but that’s just the baseline. As a rule, ethics and compliance professionals want to empower their employees, improve corporate culture and positively impact our communities. I take pride in my job knowing I’m successful when I can help my fellow compliance professionals be successful. The FDR Welcome Packet and the partnership that is created is not just good business, it’s the right thing to do.

1 COMMENT

  1. This could also mean initiating dialogues with business partners and investors that may lead to financial mobility , that could give quick access to funds mainly through digital platforms such as the web or ATMS for emergencies or reinvestment into the business for bigger returns in the medium and long term .
    The business leader or compliance officer could use this emergency fund to personally engage with his workforce directly in their various fields of operations and even offer little financial incentives to inspire them, drill into real models or structures contributing fairly to the expansion of assets in foreign or neighboring countries at low cost accommodative levels.,, spark up or ignite the imaginative ability of the business leader or compliance officer thereby blazing up the morale of the entire workforce or business etc. Even though these operational procedures may be ambitious they could still be carried out under regulatory guidelines to reduce costs and enhance efficiency. Subsequent quarterly activities could then be scaled up to reach main targets or milestones that could as well yield bigger financial gains in return.

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