Posted by: Margaret Scavotto, JD, CHC
- Without a review, you don’t know what you don’t know.
Were policies distributed? Were staff, board members, contractors, and volunteers properly trained? Were all risk areas audited? Were audit findings mitigated? Were compliance reports properly investigated and met with discipline and corrective action? Without conducting a review, you don’t know. Who would you rather identify your compliance flaws: your own organization, via a compliance review – or the government, via an audit or investigation?
- The Feds say you need it.
The OIG Compliance Program Guidance documents recommend an annual review as an essential part of an effective compliance program. If your organization is ever faced with an OIG investigation, you will want to be able to prove you have an effective compliance program to maximize your chances of mitigating penalties. This means: you need to conduct annual compliance program reviews. Plus, if your organization is a nursing home, compliance program annual reviews are required by law as of November 28, 2019.
- Compliance program review makes compliance better.
Every compliance program review will find flaws. I repeat: every compliance program review will find flaws. Even the most impressive compliance programs can identify areas for improvement. Nobody is perfect, and mistakes happen. Turnover is a reality, and can cause compliance tasks and initiatives to fall through the cracks. By assessing your program and identifying areas for improvement, you commit to making your compliance effort stronger.
- Compliance program reviews provide opportunities to recognize a job well done.
Likewise, every time I conduct a compliance program review, I find numerous examples of success: leaders who achieved 100% compliance training attendance for their team; compliance officers who diligently document follow-up on every compliance report; Directors of Nursing who use results of medical necessity audits to improve nursing documentation. The individuals behind these jobs-well-done are responsible for compliance success. Without the compliance program review process, their noble efforts could go unnoticed. Use your review report to celebrate compliance strengths and give credit where credit is due.
- “Anything worth doing is worth doing right.”
I am quoting my dad here, but his favorite parenting advice is suitable. It takes a lot of work to implement a compliance program with leadership, policies, training, and audits. Skipping the compliance program review does your compliance effort a disservice. It’s kind of like buying a new Lexus but not bothering to get regular maintenance. At some point, something will go wrong with that car – and you will be the last to know.