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by Madeline Angela Meyer and Michael Alan Meyer

General Healthcare Compliance Plans

In last week’s article, we looked at what CMS and the RACS programs have to offer providers and other healthcare professionals in the way of training, continuing education and audit tools for maintaining healthcare compliance. Today’s healthcare facility doesn’t have just one overarching compliance plan, but rather volumes of plans, policies and procedures to meet many requirements under current laws.

Healthcare Facility Compliance Plans are generally broken down into three (3) basic areas, e.g., 1) operational compliance, or regulatory compliance which involves everything related to patients, patient safety and human resources, 2) financial compliance, e.g., policies and processes related to the revenue cycle, contracting and all matters of finance, 3) health information management and technology compliance, which includes HIPAA and HITECH Acts.

Compliance plans should follow the seven (7) the principles of the U.S. Sentencing Guidelines, to ensure that all areas of compliance have been adequately covered. The principles are:

1. Standards and Procedures: Establishment of written compliance policies and procedures and distribution to employees.

    o The Organization’s Code of Conduct

2. Oversight: Designation of a specific individual or individuals to monitor compliance.

    o The Compliance Officer and/or Compliance Committee).

3. Education and Training: Commitment to conducting formal, documented training and education programs.

    o Ongoing training on the standards and procedures.

4. Auditing and Monitoring: Development of internal system for communication of suspected compliance violations.

    o Verifying compliance.

5. Reporting: Commitment to auditing and monitoring to evaluate compliance and identify potential problematic areas.

    o Reporting concerns and developing corrective plans.

6. Enforcement and Discipline: Maintenance of disciplinary policies which are consistently enforced.

    o Non-compliance policy enforcement consistent with appropriate disciplinary action.

7. Response and Prevention: Development of process for investigation of suspected violations and reporting to the government and law enforcement authorities when necessary.

    o Process for employees to voice their concerns.

Healthcare Compliance Technology

Compliance survival for any size medical facility today requires strong technological infrastructure in order to meet the challenges. Partnering with quality information system vendors and transforming health services and compliance through technology is an absolute necessity in 2012 and beyond.

The attached presentation are some of the ways that healthcare facilities are achieving highly automated, integrated, and relational database technologies that communicate through their electronic medical billing systems in order to perform high level compliance monitoring and reporting.

See: Technology Partnerships: Compliance Planning!


United States Sentences Commission. (2012) US Sentencing Guidelines. http://www.ussc.gov/

DHHS. (2012) OIG Compliance Program for Individual and Small Group Physician Practices, 65 Fed. Reg. 59434 (Oct. 5, 2000).

DHHS. (2012) Compliance Guidance. Office of the Inspector General. https://oig.hhs.gov/compliance/compliance-guidance/index.asp


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