There are a lot of good reasons to do a periodic review of your healthcare compliance program, not the least of which is that the government expects it.
But when’s the right time? How do you get the management support? What outside experts do you need? And how do you integrate the results into your workplan?
Those questions are tackled by Anne Daly, Vice President of Compliance, Samaritan health System, Judy A. Ringholz, Vice President of Compliance and Ethics & Chief Compliance Officer, Jackson Health System and Steven W. Ortquist, Founder & Principal, Arete Compliance Solutions in this podcast and at their session “How to Assure that Your Next Compliance Program Review Confirms Performance and Helps Improve Your Compliance Program” at the 2022 HCCA Compliance Institute.
It’s important, they explain, to make sure that you have your arms around the program before you begin the review. If you’re new to the role, you probably don’t know enough about the program to make the review as successful as it could be.
Once you feel that you are ready and that it’s time to have outside eyes review the program, it’s important to select a vendor with healthcare-specific experience, ideally with experience interacting with enforcement. Make sure they also have a solid understanding of the government’s expectations as well as your organization’s goals. Be sure they also are well versed in the fiduciary duties of healthcare boards and have the personal presence to be able to present to the board.
One thing else to do: make sure the consultant is reasonable. You want someone who will give you actionable recommendations, not someone caught up in a quest for perfection.
Be prepared to dedicate significant staff resources to help the review, most likely including a dedicated person who will be on point for the project. A consultant is going to need your team to provide a lot of documents about the program and assistance in scheduling interviews with key employees.
Once the work is done and the report is drafted, it’s a good idea to review it with the consultant to make sure that he or she truly understands the organization and didn’t misinterpret any information.
Be sure also to meet with the board and key leadership so that they understand the purpose and benefits of the review, including that it is a part of their fiduciary duty to have an effective compliance program.
And, be sure to bring your workplan to the final presentation to the board. That’s an ideal time to both demonstrate what you plan on doing and ask for the resources you need to get the job done.
Listen in to learn more, and then join us in Phoenix (in person or virtually) March 28-31 for the 2022 HCCA Compliance Institute.