Module 05 Course Project - Procedures for Compliance
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Compliance Procedures
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Compliance Procedures
In module 3, compliance policies were developed for two compliance plans. Normally, policies set out rules and parameters of what needs to be done. However, what needs to be done and how should be done are two different concepts. It is possible medical facilities could be having progressive compliance policies but the effect will be determined by how these policies are implemented. Process or steps which outline how compliance policies are implemented in the medical facility for two compliance plans is known as compliance procedure.
Compliance Procedure for Covid Protocols.
It has been established that the health sector is one most hit by COVID-19 in the United States with approximately 4% of healthcare professionals succumbing to the virus. However, even with such a glaring dangerous infectious which continues to destabilize the healthcare system, cases of violation to handwashing were noted in our medical facility. It is on the background of this compliance policies were written in project 3- that is standard protocols that entail precaution practices such as hand washing and PPE and, communication policy to relay information on prevention to medical staff and clients (Beyamo, Dodicho & Facha, 2019). However, having compliance policies is not adequate and that is why compliance procedure has been developed.
Compliance procedure to implement standard COVID protocols and communication policy comprises of five steps/processes. These processes are outlined below and every medical staff is invited to read and familiarize themselves with the laid down procedure.
Step 1: The compliance officer develops standard precautions that medical staff should comply with to minimize the spread of the virus. Compliance officer needs to research and consult with the ministry of health, world health organization and CDC to establish standard precaution that relates to COVID protocols.
Step 2: Compliance officer shares with management on standard Covid protocols that is a standard precaution which facility need to implement to prevent the spread of the virus. This will enable management to procure medical devices such as an apron, gloves, surgical face mask, and sanitizers and hand washing points to be put in the medical facility (World Health Organization, 2020; Beyamo et al…, 2019). This is very important because it helps to ensure necessary medical devices required to implement precaution measures are available.
Step 3: Compliance officer avail publication to medical staff which outlines standard precaution measures that have been recommended by management. In the publication, another standard precaution which medical staff should implement, a statement of administrative and disciplinary action statement which is meant to reinforce standard precaution. Additionally, the publication states that medical staffs have the right to demand to be provided with effective and adequate PPEs before they attend to the clients (Sheldon, 2019). Therefore, management must ensure that the medical facility has adequate and recommended PPEs to offer medical staff protection and minimize the spread of the virus among colleagues, family members and clients.
Step 4: Training session for medical staff. A compliance officer will organize a training session that will incorporate management officials and guests from the ministry of health. The training session will seek to educate medical staff on how to put PPEs and other standard precautions measures that should be observed when attending to patients. Further, training will create awareness of the importance of observing standard COVID protocols that relate to precaution measures.
Step 5: The compliance manager will develop a communication framework that is tailored to educate clients on COVID regulations which are implemented in the medical facility. At the entrance of the medical facility, clients will be made aware of the existence of COVID, prevention measures that have been put in the facility and obligations of clients in containment effort.
Procedure for Billing Plan
A billing compliance plan was developed for the medical facility after it was revealed some staff that bill clients charge them twice. This is unacceptable and against the code of ethics for Medical facilities. The facility is against the exploitation of clients and is committed to remaining a truthful and trusted institution. However, this cannot be attained when some employees want to take advantage of clients who possibly do not have knowledge of systems used to charge clients. Such practices are not only rampant in our medical facility and also in public health facilities. It is for this reason Medicaid Fraud Control Unit instituted a system to prosecute healthcare personnel that fraudulently exploit clients by charging healthcare services that otherwise are provided freely (Flasher & Lamboy-Ruiz, 2019). Cognizant of billing violations in the medical facility, related compliance policies were developed, which entails ethical standards of professionals in the billing process and also auditing. However, to ensure that compliance policies are complied with and implemented to the latter, a compliance procedure for billing compliance plan has been developed.
Procedure 1: Compliance officer liaises with diagnosis medical officers to develop codes that will be used coding. It is the medical officers that see patients determine what to charge depending on the service rendered. Therefore, it will be necessary for the compliance officer to connect with healthcare personnel that attends to patients and comes up with codes that will be submitted to the billers.
Procedure 2: Compliance officer shares with billers developed codes. To enhance clarity to the biller, codes that have been developed will be shared by the individuals that bill clients, prepare and submit claims to Medicaid, Medicare, private health care insurance providers and third parties. This will help to ensure billing is systematic and consistent and issues of duplications in the billing are avoided.
Procedure 3: Training on compliance with billing codes. A compliance officer will undertake a training exercise that seeks to educate billing officers on the need to comply with billing codes that have been developed.
Procedure 4: Auditor's requirement. A compliance officer will outline the requirements of auditors and the job description of auditors recruited by the medical facility. The medical facility is determined to enforce internal control systems to strengthen its billing system and also enhance transparency and fairness of the system. This compels the facility to institute a monitoring system through recruiting internal and external auditors. For internal auditors, the company will recruit individuals with a high code of ethics for auditors, qualified auditors with knowledge of international auditing standards and also, an individual conversant with the billing process in a healthcare setting. Internal auditors will regularly monitor billing systems and establish whether billers are complying with coding systems that have been developed as well as management policies.
For external auditors, the medical facility will recruit auditing firms that have demonstrated a strong stand for audit independence. External auditors will annually audit billing systems and establish whether internal controls are adequate and implemented and two, will help detect whether there are fraudulent activities committed by billers (Younas & Kassim, 2019).
Procedure 5: Legal action will be taken against billers that do not comply with the billing compliance plan. Reports of both internal and external auditors will be evaluated and when malpractices are identified amongst billers, a medical facility under leadership and direction of compliance will determine disciplinary and legal action to be taken against billers that violate the billing compliance plan.
References
Beyamo, A., Dodicho, T., & Facha, W. (2019). Compliance with standard precaution practices and associated factors among health care workers in Dawuro Zone, South West Ethiopia, cross sectional study. BMC health services research, 19(1), 381.
Flasher, R., & Lamboy-Ruiz, M. A. (2019). Impact of enforcement on healthcare billing fraud: Evidence from the USA. Journal of Business Ethics, 1-13.
Sheldon, L. K. (2019). The Importance of PPE Use. AJN The American Journal of Nursing, 119(4), 10.
World Health Organization. (2020). Handwashing an effective tool to prevent COVID-19, other diseases. Retrieved from https://www.who.int/southeastasia/news/detail/15-10-2020-handwashing-an-effective-tool-to-prevent-covid-19-other-diseases
Younas, M. A., & Kassim, A. A. M. (2019). Essentiality of internal control in Audit process. Int J Bus Appl Soc Sci [Internet], 1-6.