Home Health & Hospice Week

A strong compliance plan will address all of these important areas.

Since the beginning, the HHS Office of Inspector General has advocated seven core elements for strong healthcare compliance programs. It retains and reinforces those tenets with important action items in its revamped General Compliance Program Guidance.

1. Written Policies and Procedures — covers Code of Conduct, Compliance policies/procedures and maintenance of these documents.

2. Compliance Leadership and Oversight — includes Compliance Officer designation, a Compliance Committee and Board Compliance Oversight, defines their primary responsibilities, and indicators of success.

3. Training and Education — encompasses appropriate education/training including examples of specific topics to cover and ideas on how to provide compliance-related education.

4. Effective Lines of Communication — defines contact between the compliance officer and entity personnel (including contractors and agents), development of written confidentiality and non-retaliation policies and creation of independent paths for reporting violations.

5. Enforcing Standards — includes consequences and incentives.

6. Risk Assessment, Auditing, and Monitoring — defines steps to identify, quantify, analyze and respond to compliance risk, and measurements for ongoing auditing and monitoring.

7. Responding to Offenses and Corrective Action — covers the investigation of violations, government reporting and implementation of corrective action initiatives for violations of the entity’s compliance program, failures to comply with applicable Federal or State law, or other types of misconduct.