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OIG's 7 elements for effective compliance
List published in Federal Register in 2005
When initiating or improving a research institution's compliance program, the most efficient place to start is to follow federal guidance on such programs, including compliance program guidance created by the he U.S. Department of Health and Human Services' Office of Inspector General (OIG).
The OIG's guidance no longer is voluntary for hospitals, and its seven elements of an effective compliance program remain a solid foundation for other organizations' compliance efforts. The guidance published Jan. 31, 2005 (Vol. 70, No. 19) in the Federal Register, as the OIG Supplemental Compliance Program Guidance for Hospitals, lists these seven factors the OIG believes may be useful when evaluating the effectiveness of basic compliance program elements.
They are as follows:
1. Designation of a compliance officer and compliance committee.
The OIG states that the compliance department is the backbone of the hospital's compliance program and should be led by a well-qualified compliance officer, who is supported by a compliance committee. The OIG suggests organizations consider a number of questions, including this sample:
2. Development of compliance policies and procedures, including standards of conduct.
Compliance policies and procedures should be designed in a way that helps employees remain in compliance while carrying out their job functions, the OIG recommends.
Here are some excerpts from what the guidance suggests that hospitals consider:
3. Developing open lines of communication.
The OIG describes open communication as a product of organizational culture and internal mechanisms for reporting instances of potential fraud and abuse.
Here is a partial list of factors hospitals might consider:
4. Appropriate training and education.
Failure to train and educate staff adequately creates risk liability for the violation of health care fraud and abuse laws, according to the OIG.
Some of the factors OIG asks hospitals to consider are:
5. Internal monitoring and auditing.
With effective auditing and monitoring plans, hospitals might avoid submitting incorrect claims to health care program payers, the OIG says.
These are a few of the factors the OIG believes they should consider:
6. Response to detected deficiencies.
The goal is for hospitals to respond consistently to all detected deficiencies and develop effective corrective action plans to prevent further losses to federal health care programs.
The OIG's recommended factors to consider include some of these:
7. Enforcement of disciplinary standards.
Hospitals can create an organizational culture that emphasizes ethical behavior and which considers these factors, among others: