Transcript Developing an Effective Compliance Program

Developing and
Implementing an
Effective Compliance
Program
Mary Sacilotto,BA,CHC
Chief Compliance Officer
Alliance, Inc.
Establishing a Commitment to
Compliance
Board of Directors
 President/CEO
 Chief Compliance Officer
 Essential Compliance Staff
 Compliance Committees
 Legal Counsel
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Hiring a Compliance Officer
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Experienced in management
Trusted and respected
Effective communication skills
Strong leadership skills
Self-confidence
Stamina
Must have direct and regular contact with the
Board of Directors
Compliance Guidance
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Health Care Compliance Association (HCCA)
(www.hcca-info.org)
U.S. Federal Sentencing Guidelines
U.S. Department of Health and Human Services
(HHS)
 Office
of the Inspector General
(http://oig.hhs.gov/index.html)
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Centers for Medicare and Medicaid
(http://www.cms.hhs.gov)
Seven Elements of an Effective
Compliance Program
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Written Standards of Conduct
Designate a Chief Compliance Officer & other
appropriate bodies – Compliance Committees
Effective Education & Training
Audits and Monitoring
Reporting and Investigating
Appropriate Disciplinary Mechanisms
Response & Prevention
Project Management Plan
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Create standards for compliance (conduct, conflict of interest, fraud &
abuse, disclosure)
Establish a formal relationship for legal compliance referrals
Implement an anonymous hotline as a reporting mechanism
Implement compliance complaint logs
Develop a compliance program training that outlines organizational culture
of corporate ethics
Develop educational presentations programs for Board
Establish Compliance Committees – Board and Internal
Implement an ongoing audit schedule
Expedite investigations and remedy alleged misconduct
Review current policies & procedures for compliance
Measure effectiveness of program ( surveys, focus groups, trend analysis)
Compliance Work Plan
Develop an annual work plan
 OIG work plan
 Semi-annual risks assessments
 Audits (internal & external)
 Regulatory requirements
 Seven elements – education, training
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Establish Compliance Policies
Code of Conduct
 Conflict of Interest Policy
 Non-Retaliation Policy
 Whistleblower Policy
 Anonymous Reporting Tool
 False Claims Act
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Championing Compliance
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Meet with Program Directors/Managers
Facilitate Risk Assessments
Conduct Mandatory Compliance Training
Attend Staff Meetings
Conduct Focus Groups
Be visible and keep an open door policy
Establish a rapport
Be flexible and keep an open mind
Sustaining a Compliance Program
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Considered a work in progress
Constantly changes to adapt to the needs of the
company
Develop an Annual Work Plan and assess
regularly (approved by Board of Directors)
Remain on the cutting edge by taking advantage
of conferences and training opportunities
Establish credibility
Questions?