The Art of Communication and the Compliance Message

Posted By:

Bret S. Bissey, MBA, FACHE, CHC, CMPE

In the August 2014 issue of Compliance Today,

Bret S. Bissey, MBA, FACHE, CHC, Senior Vice

President, Compliance Services with MediTract

authored an article about the impact of today’s

communication message and methods on compliance programs.

As a former compliance officer (with over 10 years

experience), I am asked frequently about the seven

elements of compliance and specifically, which is the

most important?

My response is that you really cannot do effective

and impactful compliance without all seven being in

place. Some like to refer to each of the elements as

the “blocking and tackling” of your compliance program.

To further explain and demonstrate the point, it is like

asking a college football coach which is the most

important aspect of their program—is it offense,

defense, special teams, line play, the quarterback,

the fullback, recruiting, etc.—hopefully you get the

point: If one element fails, your program probably

isn’t ever going to reach its full potential.

But there is one compliance program element,

education and training, that I would like to analyze as

it relates to today’s evolving methods of

communication (sometimes impersonal) and the

impact it has on your compliance program.

So let’s go way back to the beginning of compliance

guidance from the Office of Inspector General’s

Model Compliance Program for Hospitals (1998) and

review the direction given regarding education and training, as follows:

• The proper education and training of corporate

officers, managers, employees, physicians,

and other healthcare professionals, and the

continual retraining of current personnel at all

levels, are significant elements of an effective

compliance program.

• A variety of teaching methods, such as

interactive training and training in several

different languages, particularly where a

hospital has a culturally diverse staff, should be

implemented so that all affected employees are

knowledgeable of the institution’s standards of

conduct and procedures for alerting senior

management to problems and concerns.

• The OIG suggests that all relevant levels of

personnel be made part of various educational

and training programs of the hospital.

Employees should be required to have a

minimum number of educational hours per

year, as appropriate, as part of their employment responsibilities.

• The OIG suggests that all relevant levels of

personnel be made part of various educational

and training programs of the hospital.

Employees should be required to have a

minimum number of educational hours per

year, as appropriate, as part of their employment responsibilities.

For more information visit

http://www.meditract.com/resource-

center/some-thoughts-on-tone-at-the-top/.