The Seven Elements Of A Compliance Program PDF Print E-mail

A compliance program is an organized initiative to detect ongoing and potential noncompliance with legislation, to correct noncompliance, and to guard against future violations. A compliance plan is a detailed, written tool designed to implement your program.

Review your current practice policies, procedures, arrangements, relationships, and business practices. Immediately correct any actual or potential violation you discover. The actual and often unique nature of any problem discovered will dictate corrective measures to be taken.

To develop a compliance program that is suited to your practice, consider these seven basic compliance plan elements, as recommended by the Office of the Inspector General.

Establish a compliance training and education program for all practice physicians and employees.

  1. Install a system to respond to allegations and complaints. Make sure it is in accord with your policies and procedures.
  2. Establish evaluation tools and techniques to monitor compliance and address existing and potential problems.
  3. Investigate and address all problems. Make it your policy to discipline- even dismiss-practice members who are noncompliant or foster noncompliance.
  4. Provide protection for practice members who point out existing and potential compliance problems and issues.
  5. Appoint a compliance officer responsible for implementing and monitoring compliance.
  6. Write it down. Include all compliance policies and procedures. Address fraud areas and elements that are specific to your practice and specialty.
Compliance planning takes time, research, and a certain degree of expertise, particularly legal know-how. A plan that is poorly drafted or left in a desk drawer and not implemented cannot benefit your practice and may actually hurt it.

When done correctly, compliance planning is a wise investment in your practice's future


Written by: Joan M. Roediger, JD
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