effective compliance in small organizations · 3/4/2011 11 federal sentencing guidelines ethical...

3/4/2011

1

Effective Compliance

in Small OrganizationsFaith Jones, MSN, RN, NEA-BC

Kara Beech, BS, CHC

Objectives

• Analyze current position functions to imbed

compliance into the foundation of your

organization

• Enhance relationships throughout the

organization that will increase your

compliance foundation

• Utilize the network of knowledge to assign the

various hats within your organization

3/4/2011

2

What is Compliance?

Who are you accountable to?

What regulations do you follow?

Group Exercise

Source: Hospitals and Health Networks Magazine, April 2001

Your

Organization

3/4/2011

3

Overwhelmed Yet?

Can your compliance program be

everything to everybody?

Rest assured, you are already doing more

than you think.

Where do you Start?

• Visualize building your program from the

bottom up.

• And the foundation is……..

Federal Sentencing Guidelines

3/4/2011

4

Foundational Building Blocks

• Federal Sentencing Guidelines

– Standards of Conduct/Policies & Procedures

– Compliance Officer and Compliance Committee

– Education

– Monitoring and Auditing

– Reporting and Investigation

– Enforcement and Discipline

– Response and Prevention

Federal Sentencing Guidelines

Federal Sentencing Guidelines

Ethical Culture

Do the right thing,

for the right reasons,

in the right way.

Building your Program

3/4/2011

5

Federal Sentencing Guidelines

Ethical Culture

Co

de

s o

f C

on

du

ct

Po

lici

es

an

d P

roce

du

res

Policy and procedure

development is the

framework that builds on

your ethical culture.

Building your Program

Federal Sentencing Guidelines

Ethical Culture

Co

de

s o

f C

on

du

ct

Po

lici

es

an

d P

roce

du

res

Compliance

Committee

&

Compliance

Officer

Building your Program

Talent Acquisition

It’s an in-house search!

3/4/2011

6

Talent Search

• Compliance Officer

– Access to the Board of Directors

– Report to Senior Level Executive (CEO)

• Role

– You may need to wear several hats

– You’re the Mayor, not the Sheriff

Compliance

Committee

&

Compliance

Officer

Talent Search

• Compliance Committee

– Not a repository of reports, but a work group of

information sharing

– A working committee made up of personnel with

varied expertise

• Commonly known as “Other duty as assigned”

• Align innate abilities with specific compliance functions

• Compliance is everyone’s job Compliance

Committee

&

Compliance

Officer

3/4/2011

7

Seeking Experts

• Education background

• Past work experience

• Communication/education/training skills

• Personality types

• Life long learners/self starters

• Problems solvers

Talent Search Sources

• EMTALA Expert

– Trauma Coordinator, OB Nurse, Triage Specialist, Admission Coordinator, etc.

• HIPAA Expert

– Medical Records specialist, Receptionist/PBX Operator, IT specialist, etc.

• Billing & Coding Experts

– Medicare Biller, Collector, Coder, Utilization Review, Case Management, etc.

• Think beyond the management team

3/4/2011

8

Talent Search Sources

What experts would you need for a well

rounded compliance program?

Group Exercise

Federal Sentencing Guidelines

Ethical Culture

Co

de

s o

f C

on

du

ct

Po

lici

es

an

d P

roce

du

res

Compliance

Committee

&

Compliance

Officer

Building your Program

3/4/2011

9

Educating the Experts

• Become a member of HCCA

• Identify a researcher

• List Serves (HIPAA Weekly Advisor, Compliance

Update, TWCC, etc.)

• Websites (OIG, CMS, HCCA, HcPro, etc)

• Networking

– Look around the room and use your break

time wisely

Federal Sentencing Guidelines

Ethical Culture

Co

de

s o

f C

on

du

ct

Po

lici

es

an

d P

roce

du

res

Compliance

Committee

&

Compliance

Officer

Building your Program

3/4/2011

10

Monitoring and Auditing

• You can’t do everything

• You will be amazed at what you can build one

piece at a time

• Take credit for what you do

• Reinforce your accomplishments

to sustain your results.

• M&A protects your program.

Approach to New Regulations

• Researching and being aware of the trends and conversations prior to it becoming a law/rule.

• How did you find out about it?

• Who is your subject matter expert?

• Is anyone else doing anything similar on the subject? (Do not duplicate work!)

• Develop a policy and procedure

• Education staff

• Monitor and audit the process

3/4/2011

11

Federal Sentencing Guidelines

Ethical Culture

Co

de

s o

f C

on

du

ct

Po

lici

es

an

d P

roce

du

res

Compliance

Committee

&

Compliance

Officer

Program Structure

A structure that will withstand the implementation of new regulations, as well

as investigating, disciplining, and reporting issues of non-compliance.

Resources American Hospital Association www.aha-solutions.org

Compliance 360 www.compliance360.com

HCCA http://www.hcca-info.org

HCPro www.hcpro.com

HHS OIG www.oig.hhs.gov

Meade & Roach www.meaderoach.com

SCCE http://corporatecompliance.org

The Healthcare Compliance Blog www.thecomplianceblog.com

A Compliance & Ethics Program on a Dollar a Day: How Small Companies Can Have Effective Programs by Joseph E. Murphy, CCEP

Compliance 101 by Debbie Troklus, CHC, and Greg Warner, CHC

The Health Care Compliance Professionals Manual by CCH & HCCA

3/4/2011

12

Contact Information

Faith Jones, MSN, RN, NEA-BC

fjones@barretthospital.org

Kara Beech, BS, CHC

kbeech@pvhc.org