The Seven Necessary Components of a Corporate Compliance Plan
According to Kowal (1998), this plan involves applying written procedures to establish the stakeholder expectations regarding the organization’s practices. Second, the plan should involve designating a compliance officer and contract to oversee the policy and program. Third, conducting training and educational programs for the workforce are critical components of a compliance plan. Fourth, the development of effective communication lines between the officers and employees is crucial in the policy. Fifth, a compliance policy should include internal monitoring and auditing practices, a strategy necessary for the program’s success. Sixth, a compliance plan should comprise of publicized disciplinary guidelines to enforce the standards of the corporate. Lastly, the policy should include prompt responses to detected offenses and the steps for undertaking the necessary corrective action.
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The Roles and Responsibilities of the Staff Who Implement a Compliance Plan
Rupper (2013) posits that every compliance personnel develops a program for preventing, monitoring, and detecting the fields that require corrective actions. In addition, this individual recommends policies and procedures to the administrative departments to ensure compliance with federal regulations. Furthermore, the compliance officer investigates issues arising from organizational audits and provides recommendation for the necessary corrective action. Nonetheless, the individual assures that the training processes are in accordance with the management strategies of the firm. The roles of the chairpersons in the plan are to appoint the Unit Compliance Managers and help in the implementation of corrective action plans to maintain departmental compliance. Subsequently, the Unit Compliance Managers oversees the development of quality control process and implementation of regulatory changes. Moreover, the manager tracks the completion of training programs for staff and unit faculty and develops corrective actions for non-compliance with an organization’s regulations.
The Roles and Objectives of Healthcare Enforcement Agencies or Programs That Influence Noncompliance Reporting
Emergency Protocols – healthcare programs regarding nurse responses to emergencies involve rationing time to provide care to patients. During this rationing, the practitioners might lack sufficient time to perform compliance-reporting practices because their key concern is to protect the patient’s life.
The Procedure for Reporting Coding Noncompliance
Employees might report coding noncompliance issues in writing or verbally. Subsequently, an individual can report concerns to the compliance offer, the general council, chairpersons, or the unit report station. The reporting of these coding noncompliance issues should occur in a confidential platform in an organization’s common work areas. In addition, employees might make confidential calls to the compliance officer to report the noncompliance subject. Subsequently, the compliance officer should maintain a portfolio of concerns reported to his/her office. Furthermore, the department should treat this portfolio as confidential and limit access to individuals responsible for noncompliance reports. After determining the presence of a reasonable noncompliance cause, the officer should conduct enquiries among the staff and develop an appropriate action to address the issue.
The Coding Compliance Auditing Process
Response to a Formal Request for an Audit by an Internal Reviewer
An audit by an internal reviewer is crucial in ensuring that a healthcare organization recognizes, monitors, and corrects coding compliance challenges (Averill, 1999). Subsequently, audits by internal reviewers will enable the firm to identify noncompliance patterns before an external reviewer assess penalties. Before the process, the organization should adopt a monitoring program and a compliance audit. Subsequently, the existence of an effective documentation platform shows that the coding noncompliance was unintentional (Averill, 1999). As a result, the internal reviewer should examine the reports of physician services and their frequencies. Nonetheless, a healthcare organization should obtain a current frequency data from national medical specialty before and during an audit. Furthermore, the internal auditor should review the organization’s supporting documents and compare them with the services performed.
Response to a Formal Request for an Audit by an External Reviewer
In response to an audit request by an external reviewer, a healthcare organization should identify and document its goals and objectives. The identification of goals will ensure that the audit feedback is in accordance with the institution’s objectives (Averill, 1999). Furthermore, the identification of goals will help the directors to develop effective recommendation that drives the audit process. Since quality coding affects the organization’s administration, the executive should support the audit process, serving as a sponsor for the procedure. Using the company’s coding claims and documentation, the officers can determine the cases, trends, errors, and provider claims for review (Averill, 1999). During the process, a healthcare organization should have at least two auditors on-site to keep the coders positive. Finally, the organization should coordinate with the external reviewer during and after the auditing process to add value and increase trust in the firm.
Response to Audit Results Showing a Coding Practice Resulting In Overpayment
Corrective action is necessary against stakeholders who violate an organization’s compliance programs. In case of audit results showing overpayment, the supervisor should initiate internal investigations immediately (Averill, 1999). Accordingly, the compliance officer should implement corrective actions to prevent the recurrence of the coding program. Delays in implementing the corrective actions might depict a wrong message to the employees who are aware of the overpayment. If the government conducts investigations and discovers the organization was aware of the situation and failed to react, it might increase penalties due to recklessness. However, the government is less likely to issue sanction in case the management corrects and prevents the recurrence of the problem. Nonetheless, the corrective measures should include employee education, workforce discipline, the development of new policies, and the modification of the firm’s computer system. Finally, the organization should refund the affected individuals.
- Averill, R. F. (1999). Monitoring Coding Compliance. 3M HIS Research Report 4-99.
- Kowal, S. M. (1998). Corporate compliance programs: A shield against criminal liability. Food & Drug LJ, 53, 517.
- Rupper, M. (2013). Roles and Responsibilities – Corporate Compliance and Internal Audit (1st ed.). Colorado: Ahia Association of Healthcare Internal Auditors. Retrieved from https://www.ahia.org
