Compliance Best Practices for Boards of Healthcare Institutions
Quality hospital and patient safety is an important priority in our nation. Often, we learn much from investigating the results of adverse events and health crises. Obviously, it’s better to be proactive in identifying potential risks and put systems and equipment in place to prevent problems.
The Office of Investigator General (OIG) offers some strategies for best practices for boards of healthcare institutions. Another viable place for healthcare institutions to discover best practices is by looking at the best practices of other healthcare institutions.
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Compliance best practices are a work-in-progress and will be for some time in the future. The best-laid compliance plans for hospitals build on the knowledge, expertise and programs of previous years.
OIG Offers Annual Work Plans for Healthcare Compliance Programs
One of the best places to find best practices for healthcare compliance programs is on the website of the OIG. Following are seven recommendations for best practices from the OIG:
Designate a compliance officer and a compliance committee.
The OIG recommends that healthcare institutions select a member of senior management who has access to the board of directors, the chief executive, senior managers and lawyers to serve in the role of compliance officer. The compliance officer should have the support of a compliance committee composed of various facets of the organization and key managers of key operating units, including finance, audit and human resources. Compliance officers should regularly report to the board as part of their duties.
Develop compliance policies and procedures, including standards of conduct.
The hospital’s code of conduct is designed to identify risks for employees on every level. The goal of policies and procedures is to help employees comply with the requirements of the federal healthcare program requirements as they work toward fulfilling the institution’s goals and objectives. Institutions should ensure that all directors, officers, managers, employees and third-party vendors are aware of these policies.
Develop open lines of communication.
Communication is a best practice that healthcare and other types of institutions often take for granted. The OIG suggests utilizing newsletters, compliance intranet websites and anonymous hotlines for reporting compliance issues. The board of directors should be made aware of all potential issues of fraud and abuse and receive copies of all fraud and abuse investigations.
Provide appropriate training and education.
Healthcare boards should ensure that they have the appropriate training and education on healthcare rules, regulations and standards, including knowledge of fraud and abuse laws. Boards should ensure that healthcare institutions’ employees, contractors and others that act on the hospital’s behalf also receive appropriate training and education.
Monitor and audit compliance issues internally.
As part of internal controls, boards of healthcare institutions should perform regular audits and risk assessments to help identify potential areas of concern and work toward reducing risks. The OIG suggests that boards should pay special attention to the processing of billing and claims activities.
Respond to detected deficiencies.
Internal controls, reporting and compliance are important activities that are the precursors to responding to compliance risks. As part of best practices, the OIG recommends that hospitals form a response team that includes members of the audit committee, compliance staff and other staff to streamline the process of identifying compliance deficiencies. Not responding to identified deficiencies creates the additional risk of negatively affecting a hospital’s mission and reputation, and can also have legal implications.
Enforce disciplinary standards.
Communication efforts should extend to enforcing disciplinary standards across all hospital personnel. Hospitals also need to ensure that they’re enforcing the standards consistently and with fidelity.
The collective impact of these actions will help to reinforce an organizational culture of strong ethics and integrity.
In addition to these recommendations, healthcare institutions should be aware of the following best practices:
Compliance for Healthcare Institutions Should Be Customized
The OIG cautions healthcare institutions to be aware of “cookie-cutter” compliance plans, such as using templates that are easily available with internet searches. The healthcare industry is highly complex and riddled with risks from many sources. What may be high risk for one institution may carry much lower risks for other institutions. It’s crucial for healthcare institutions to work toward customizing and tailoring their compliance programs to fit their unique needs. Taking this step will require investing the proper time and pulling from the most appropriate resources.
Carve Out Room for Ethics in Your Healthcare Culture and Compliance Program
Establishing an ethical culture goes a long way toward developing effective compliance best practices. The key to implementing consistent disciplinary measures is to have clear behavior standards for all. There is much value in establishing processes to evaluate why an error or a negative event occurred. Patients, families and staff are more likely to report issues when they feel that the healthcare institution fosters a just and fair culture. In essence, an ethics and compliance program, along with good attitudes, ensure good behaviors. Creating beliefs and incentives for doing the right thing will have a positive impact on behavior.
Work Toward Enhancing Relationships Between Employees and the Leadership Team
While communication is a vital part of compliance best practices, boards can ensure stronger and healthier communication by encouraging closer working relationships between employees and the leadership team. This is one way to make sure that employees support compliance issues.
Compliance officers are the subject matter experts in regulations. They are the primary people with the knowledge and background information to connect compliance issues with business goals and objectives. Compliance officers should be visible and present throughout the institution and should be relied on as resources for the leadership team at all times, not just when a crisis is looming.
A BoardEffect board portal system is the central place for boards, managers and compliance officers to collaborate on compliance best practices using a highly secure platform.