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Creating a “Culture of Compliance”. Ben Burton, JD, MBA, RHIA, CHP, CHC. Objectives. What is compliance? History of Compliance programs? Responsibilities of the Compliance Department What is included in most compliance?

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Creating a culture of compliance

Creating a “Culture of Compliance”

Ben Burton, JD, MBA, RHIA, CHP, CHC


Objectives
Objectives

  • What is compliance?

  • History of Compliance programs?

  • Responsibilities of the Compliance Department

  • What is included in most compliance?

  • Where can I find information on compliance issues related to my organization?

  • What does it mean to create a “culture of compliance”


Compliance definition
Compliance Definition

com·pli·ance

noun \kəm-ˈplī-ən(t)s\: the act or process of doing what you have been asked or ordered to do : the act or process of complying

http://www.merriam-webster.com/dictionary/compliance


Early corporate compliance
Early Corporate Compliance

  • 1970s Foreign Corrupt Practices Act of 1977

    • Security and Exchange Commission investigations

    • Required maintain and file accurate information with SEC

  • 1980s and early 90s

    • Ant kickback

    • False Claims Act

    • Stark

  • 1991 United States Sentencing Commission Federal Sentencing Guidelines

    • Chapter 8 part B (effective compliance and ethics program)

    • 2004 and 2010 Amendments


Compliance 1990 to today
Compliance 1990 to today

  • HIPAA

    • Privacy

    • Security

    • HITECH (Health Information Technology for Economic and Clinical Health Act)

  • 1997 Healthcare Compliance Association (HCCA)

  • Department of Health and Human Services – OIG

  • New organizations and focus as the profession grows


Compliance department
Compliance Department

  • Keeps us all on the straight and narrow

  • External

    • Legal

    • Regulatory

  • Internal

    • Policies and Procedures


Compliance process
Compliance (Process)

  • The seven elements

    • Set rules,

    • Define who creates the rules,

    • How to let everyone know about the rules,

    • Monitor if the rules are being followed,

    • Allow people to report potential violations of the rules,

    • Enforce rules, and

    • Correct risky processes.

  • Chapter 8 Part B of the Federal Sentencing Guidelines http://www.ussc.gov/Guidelines/2012_Guidelines/Manual_HTML/8b2_1.htm


Rules
Rules

  • Who

    • BOD

    • Compliance Officer

  • What

    • Address behavior

    • Protect against non-compliant or risky activity

  • Why

    • Need a reason (purpose or policy part of P&P)

    • “Show me”


Communication
Communication

  • What

    • Rules

    • Where to find them

  • How

    • Act

    • Report


Risk analysis
Risk Analysis

  • Key to any compliance program

  • Sets the environment

  • Use the OIG work plan

  • Used to develop an audit plan


Investigation and remediation
Investigation and Remediation

  • Means to report issues

  • Method to investigate possible problems

  • Way to address and correct issues

  • Compliance programs need to be proactive


Where to start
Where to start

  • Seven elements

  • Health and Human Services

  • Research other similar organizations

    • Internet

    • Call or e-mail



Culture of compliance
Culture of Compliance

  • Documents

    • Program

    • Policy

    • Code of Conduct

  • Communicate

    • At least annually

    • The positive as well as the negative

  • Incorporate Compliance into other departments

    • HR

    • QA or QI

    • RM


References
References

  • http://oig.hhs.gov/compliance/ (Compliance page, OIG website, retrieved 7/29/2014)

  • http://www.ussc.gov/Guidelines/2012_Guidelines/Manual_HTML/8b2_1.htm (2012 Guidelines Manual Chapter 8 – Sentencing of Organizations Part B – Remedying Harm from Criminal Conduct, and Effective Compliance and Ethics Program, retrieved 7/29/2014)

  • http://www.ecfr.gov/cgi-bin/ECFR?SID=63d8829318e617d5e56b6945890c9973&page=browse (ELECTRONIC CODE OF FEDERAL REGULATIONS retrieved 8/5/2014)


References1
References

  • http://www.gpo.gov/fdsys/pkg/STATUTE-91/pdf/STATUTE-91-Pg1494.pdf (Foreign Corrupt Practices Act, retrieved 7/29/2014)

  • http://www.hcca-info.org/AboutHCCA/HCCAOverview/History.aspx (HISTORY OF HCCA: SUPPORTING COMPLIANCE IN HEALTHCARE SINCE 1997, retrieved 8/5/2014)

  • http://www.acc.com/chapters/gny/upload/report-sentencing-guidelines.pdf (REPORT OF THE AD HOC ADVISORY GROUP ON THE ORGANIZATIONAL SENTENCING GUIDELINES, retrieved 7/29/2014)


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