Home Health & Hospice Week

"While the specifics are still being ironed out through the regulatory process, we do know that compliance practices will be mandatory soon enough. [The HHS Office of Inspector General] has promoted voluntary compliance programs for years," said attorney Amanda Walker, senior counsel with the OIG, during the watchdog agency's HEAT Provider Compliance Training session on May 17 in Washington, D.C.

Following are the seven compliance elements that the Centers for Medicare & Medicaid Services has identified:

• Written policies and procedures for your compliance program, which you should share with all members of your organization.
• Identification of compliance professionals in your organization who are keeping up with federal and state requirements.
• Effective training to educate your employees on your compliance policies.
• Effective communication lines between the compliance officer and the other members of the organization.
• Internal monitoring systems, such as internal audits or other reviews. "A good compliance program will identify problems from time to time," Walker said. "If it doesn't, that's a sign that what you're doing is not working. If you detect something problematic, then you're in a position to do something about it."
• Enforcement of standards and action taken if an employee is not following the procedures.
• Prompt response to any issues that you identify.