How to Develop an Effective Healthcare Compliance Program
What you need to implement a compliance program in your facility.
- Seven elements of an effective compliance program.
- How to get started with your compliance program.
In the corporate world, addressing compliance requirements makes good business sense, but it’s not required in many industries. However, in the highly regulated, high-risk healthcare industry, a solid healthcare compliance program isn’t an optional afterthought – it’s a mandatory, high-priority part of operations that every facility must address.
The challenge? Doing it effectively and in a way that doesn’t cost an exorbitant amount of money or take valuable resources away from the main mission of top-notch patient care.
Building an effective compliance program can seem formidable, especially if you are laying the foundational elements of compliance.
To do the job right, you must create dozens of policies, procedures, processes, and systems that tackle compliance requirements. They should cover prevention, detection, and correction of fraudulent or illegal behavior and any other compliance issues.
Plus, it takes effort to make sure employees at every level understand the benefits of a healthcare compliance program. This requires communicating expectations, providing staff training, and assessing the compliance program’s strengths and weaknesses.
Daunting? Yes. Doable? Absolutely.
To help jumpstart your efforts, focus on the following seven elements of an effective compliance program. Then incorporate these key elements into the step-by-step process that follows.
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Seven Elements of an Effective Compliance Program
The good news about figuring out how to implement a compliance program at your facility is that you can tap into guidelines already developed by the Office of Inspector General (OIG).
1. Establish and adopt written policies, procedures, and standards of conduct. Having clear written policies and procedures in place that describe compliance expectations fosters uniformity within your company.
2. Create program oversight. Determine who will oversee, monitor, and enforce the compliance program and serve as your go-to company “watchdog” with questions and concerns.
3. Provide staff training and education. Employees at every level need to understand your compliance program expectations and standards to be able to comply with them. Implement a training program that clearly communicates your company’s program requirements, with an annual refresher course that reminds employees of your code of conduct and incorporates any changes.
4. Establish two-way communication at all levels. Set forth the expectation that employees should proactively communicate in a timely manner, whether that means asking compliance questions, reporting issues, or addressing ethical concerns. Include a way for employees to anonymously report compliance issues or fraudulent or illegal behavior without fear of retaliation.
5. Implement a monitoring and auditing system. You’ll need to measure the effectiveness of your corporate compliance program and identify risks. To accomplish this, develop a system of both internal and external monitoring, including formal audits.
6. Enforce consistent discipline. Develop a plan to enforce standards of conduct in a timely manner, outlining appropriate disciplinary measures for employees who fail to comply with program requirements.
7. Take corrective action. When you identify vulnerabilities or violations through monitoring and auditing, take timely, consistent action to correct the issue.
More good news – in addition to the OIG’s published guidelines, you can also access additional helpful resources (via the U.S. Department of Health and Human Services) at the Compliance Resource Portal.
With these guidelines in hand, you can now take action to incorporate these key components into an effective healthcare compliance program.
How to Get Started With Your Compliance Program
From the start, your healthcare compliance program must have a clear mandate, a prescribed authority to operate, and well-defined mission and goals. With these parameters in place, you can start building an effective compliance program at your facility.
1. Collect all of your policy and procedure documents into one system
Before moving ahead, it helps to first understand your starting point. Therefore, a good first step involves conducting a policy audit, which allows you to take inventory of existing policies, procedures, and standards of conduct.
Doing a comprehensive audit establishes a baseline and identifies any gaps in implementing policies, procedures, and standards, as suggested in the first key element above. While facilities of every size need to do this, it is especially important for healthcare systems with multiple facilities or in multiple states.
For example, by gathering policies you have already created, the process reveals how outdated or unrealistic these policies might be and allows you to update these important guidelines to better reflect current needs.
An audit can also expose a compliance gap, clearly identifying where you’ll need to write a new policy or procedure that doesn’t currently exist but should.
Depending on your facility, your policies and procedures might all be housed in a bulky employee handbook sitting on a shelf in the HR office. Or perhaps these policies and procedures are spread out across facilities since different departments might adhere to different sets of operating procedures.
To help simplify how you manage and store your policies and procedures, you might consider a policy management software like PowerDMS that maintains all your critical documents in one central, online repository.
Regardless of where you keep your policies and procedures, you will need to corral them into one location for an effective policy audit now and for easier management and oversight in the future.
2. Establish program oversight
As one of the core elements dictated by the OIG, your facility’s leadership needs to authorize a person or group with the authority to run the compliance program. That means they need to be able to write and implement policies, enforce standards, track and report on compliance, and handling compliance-related tasks from a top-down perspective.
In fact, regardless of whether or not the OIG requires a Corporate Compliance Officer (CCO) or committee, designating a person or group to manage your efforts is really the key to a well-run compliance program.
You want someone at the helm who can champion corporate integrity, accountability, and ethics, as suggested in the second key element in the above list.
When your facility invests in a designated CCO position or compliance committee, it establishes the importance of the role within your organizations. Plus, it sets the tone that they will protect the organization, hold employees accountable, and lead a culture of compliance.
3. Communicate frequently with your staff
The success of your compliance program largely depends on your effectiveness in communicating not only what employees need to do, but also why this matters to them, and where they can find the information they need.
As you kickoff (or revamp) your compliance program, all employees need to understand the importance and benefits of your compliance program, especially in terms of what your facility expects from them.
If not, they might view it as “just another set of rules to follow,” making it harder to get them on board with your efforts. To accomplish this, you need to provide clear, consistent, open communication on an on-going basis, as suggested in the fourth key element above.
And don’t make the mistake of thinking communication is a one-and-done approach – something you do only at the beginning of implementing your compliance program. Because your policies are “living documents” that will get changed and updated as needs, risks, and circumstances change, you will need to continue communicating these changes to employees in the future.
Again, using a policy management software like PowerDMS gives your staff quick-and-easy access to the most up-to-date versions of your facilities critical documents.
4. Conduct ongoing compliance training
When it comes to healthcare compliance training, think of it as taking communication a step further. The compliance training reinforces the policies and gives employees the ability to apply the information to their daily jobs, as suggested in the third key element above.
Updating your policies to reflect current needs and risks is a good first step in an effective compliance program. However, these updates will not carry much weight if employees are not aware of the policy changes or do not understand how they apply to the daily work they do.
Training to your policies helps educate employees on your facility’s expectations. Speak about specific policy elements and sections that affect how employees do their jobs.
Provide scenarios and on-the-job applications so employees can make the connection to how these changes apply to real-world situations they might encounter.
One way to save time and money when training employees? Use e-learning instead of relying on in-person workshops and seminars. An online training management software makes this an affordable education solution.
5. Monitor and review your program
A solid healthcare compliance program should not only be responsible for monitoring how well employees are complying with the policies and procedures, as suggested in the third key element above. It should also be charged with regularly reviewing and updating policies.
Establishing these processes from the outset ensures the compliance program stays relevant and does the most good down the road. Think of the monitor-and-review step as future-proofing your facility.
In fact, according to Risk Management Magazine, this review process should be done annually, at a minimum, with organizations looking to these documents as “living, breathing management tools.”
As the last step, your healthcare compliance program needs to include a set of clear, enforceable disciplinary standards and policies. Otherwise, if employees fail to comply and nothing happens, your compliance program is worthless.
Tapping into the power of a policy management software like PowerDMS helps a great deal with accountability. You can document the employees’ acknowledgment and training related to your compliance program. That way, if they are non-compliant, you have the proof that they have been given all the resources and training to do what is expected, and they have been given the opportunity to correct their actions.
In addition to electronically tracking this for each employee, PowerDMS also lets you track (at a company-wide level) all of the policies, signatures, and training each employee has completed for a full view of your compliance documents.
Building an effective healthcare compliance program can pose a formidable challenge, for sure. But as you can see, it is not only necessary, it is absolutely doable. Fortunately, you now have a roadmap to jumpstart your efforts.
By integrating the seven fundamental elements outlined by the OIG – and following the steps above – you can build an effective healthcare compliance program at your facility.