Will you be hunted or the hunter? The choice many will face is, “will I look for our problems (they will exist – no organization is compliant all the time) and find solutions or will I bury my head in the sand and wait for an auditor to knock my door?” Compliance is a critical component of any organization in healthcare.
A quick Google search of “healthcare compliance officer returned 1.75billion results.” Unfortunately I don’t have the time to read each result today, but let’s just say there is more than enough information on the importance of compliance, how to start a compliance program, or how to develop a compliance committee. Following are a few steps to get you started and a few examples of what not to do! Yes the “Don’t Do’s” are actual quotes that we have heard!
When starting a compliance program:
- To do: Identify a compliance officer.
- Don’t do: “The CFO walked up to me and told me I’m the new compliance officer…. I wonder what I do now? Think I will get a raise?” You must support your staff! Provide guidance and a plan to get the program up and running.
- To do: Supply education, training, documented authority and a budget.
- Don’t do: “I can’t give that document to you because Ms. CEO will be mad at me… or you’re just the compliance officer, it’s not a real position.” The compliance officer must have access to necessary documents, even if that means they are looking into their boss’ documents (CEO’s, CFO’s, etc.).
Policies + Procedures:
- To do: Have documented policies and procedures regarding compliance. Yes, many are required and may need to be updated each year or every other year.
- Don’t do: “Dear Ms. Auditor, I don’t know why our policies have another hospitals name in them… maybe it is because our compliance officer just downloaded sample’s online and never personalized it to our company.” Samples are great, but they must be personalized and when appropriate reviewed by counsel.
Good compliance programs find problems….great compliance programs find solutions to the problems.