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- Best Practices Selection Criteria:
- Compliance Program Assessment
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- Summary
- Achievement in the conduct and reporting of the periodic/annual assessment of the corporate compliance program that meets the requirements of element 7 of the Elements of an Effective Corporate Compliance Program.
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- Definition
- The Program Assessment is a periodic review of the progress and/or achievement of the organization’s compliance program. This assessment should be conducted by or under the direction of the Compliance Officer, and focus on the organization’s implementation of the 7 elements of an effective corporate compliance program.
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- Achievement to Warrant Finding of Best Practice
- In evaluating whether a program has achieved a Best Practice in this element, look at the following criteria for a compliance program assessment:
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- 1. Corporate Governance and Oversight. The assessment should demonstrate review of:
- governing charters for the Compliance Officer and other related personnel;
- policies regarding reporting relationships between liaisons and CCO, Compliance Committee, Board of Directors and others with oversight of the program;
- written evidence of high level management support, including Board resolutions, corporate funding of program;
- adequacy of compliance office staff and resources;
- appropriateness of delegated compliance responsibilities.
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- 2. Code of Conduct Review. The assessment should:
- adequately review content to assure it provides adequate guidance to employees concerning all major risk areas within the organization
- review the Code’s coverage of laws and regulations affecting the organization;
- include review of such important Code topics as documentation, billing and coding, conflicts of interest, workplace environment and safety, HR issues, provider relationships, gifts and gratuities;
- review how the Code has been disseminated, what employees have received it, how receipt is audited, etc.
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- 3. Review of Policies and Procedures. The assessment should:
- review the existence and content of policies regarding all major risk areas identified in the Code;
- look for and review Compliance Program related policies and procedures, such as non-retaliation, reporting process, conflicts of interest, charters for the compliance program and compliance officer;
- review operational procedures for accuracy, implementation and employee knowledge of content, including background checks, investigation of incidents, EMTALA, anti-kickback issues, safety, billing and coding.
- 4. Internal Controls. The assessment should determine the adequacy of:
- internal audit reviews in the major compliance risk areas of the operation;
- targeted auditing of billing and coding issues, coverage issues, OIG identified Fraud Alert areas and other identified high profile enforcement issues;
- all audit protocols, investigation procedures, and reporting processes;
- compliance office coordination with Legal Department, HR, Internal Audit, Medical Records, etc concerning investigation, and ongoing audit/reviews.
- 5. Internal Reporting Process. The assessment should review and evaluate:
- operation of the confidential phone line (or other formal reporting mechanism);
- use of inhouse/outside resource to operate reporting program;
- training of staff which coordinates phone line and/or receives reports from outside hotline operation;
- procedures used to receive, record and protect information;
- process of investigation and follow up to reports, including providing feedback to callers;
- other reporting channels within organization, including decision tree steps;
- organization’s protection of reporters, response to allegations of retaliation.
- 6. Education and Training. The assessment should evaluate:
- content of all compliance training, corporate values focus, company commitment to ethical practices, participation of management in presentation;
- delivery and audit of training program, percentage of employees who received it, support of management/supervisors;
- how training is provided (e.g., face to face training vs electronically), feedback from participants, use of case studies
- 7. Corrective Actions. The assessment should review and evaluate:
- implementation of corrective action following investigation/determination of violations;
- consistency of all disciplinary decisions;
- timeliness, appropriateness and thoroughness of corrective action;
- record keeping of all disciplinary actions, corrective action plans;
- follow up to, and implementation of all corrective action plans;
- managers and supervisors support of all disciplinary decisions and corrective actions.
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