HEALTH CARE COMPLIANCE 1 (HEALTH INFORMATION MANAGEMENT)
Chapter 9
Role of Compliance Officer
Learning Objectives
Organization status of the Compliance Officer
Relationship with governing board
Legal and business arguments for the Compliance Officer position
Value produced by a Compliance Officer
Functions performed by a Compliance Officer
Typical qualifications of a Compliance Officer
Introduction
It is mandatory that health care organizations create and maintain an effective compliance program. For that to happen, the organization must appoint a Compliance Officer.
The Compliance Officer fills a critical position. The ability of the organization to avoid violations of federal laws, regulations, and program requirements depend on how well she/he performs the job.
Legal Rationale for a Compliance Officer
OIG compliance guidances call for designation of a Compliance Officer
Federal Sentencing Guidelines offer lower fines for programs with Compliance Officers
Presence of a Compliance Officer may reduce likelihood of charges and mitigate penalties in criminal cases
Business Rationale for a Compliance Officer
Persistently watches legal and ethical conduct across the organization
Constant reminder to managers and employees of organization’s commitment to compliance
Protects against most severe penalties
Actions boost reputation and brand name
Creates high-integrity culture that raises employee morale, while attracting customers, partners, and investors
Location and Title of the Compliance Officer
Chief Ethics and Compliance Officer, or some variation that suggests status and authority
Member of the C-suite, reporting directly to the CEO & with access to the governing board
Not serve simultaneously as chief legal or financial officer
Need not be full-time in smaller organizations
Open communication channels to and from all employees, vendors, agents, and patients
Scope of Responsibility
Single high-level official responsible for defining and enforcing the organization’s behavioral standards
Accountable for the performance of the compliance program, whether success or failure
Participates in major organization decisions that bear on compliance and ethics
Focuses fixatedly on compliance and ethics
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Job Responsibilities (I)
Lead organization’s entire compliance effort
Keeps up-to-date knowledge of legal requirements and ethical standards
Identify areas of high risk for non-compliance
Keep owners, BOD, and CEO informed of compliance risks and efforts to address them
No fear of reprisal from management
Job Responsibilities (II)
Coordinate department compliance activities
Supervise compliance program staff
Communicate compliance information to employees, agents, vendors, and customers
Work with outside third parties that may affect the organization’s compliance
Coach employees on compliant behavior
Job Responsibilities (III)
Help promote commitment to ethical, compliant behavior
Regularly assess program’s performance
Regularly measure effectiveness
Foster an ethical culture throughout the organization
Serve as primary organizational resource for reimbursement and regulatory information
Compliance Officer Qualifications
Experience in managing people
Ability to work with high-level stakeholders
Familiarity with business operations
Familiarity with organization’s industry
Detailed knowledge of compliance issues
Strong personal sense of ethics
Free from conflicts of interest
Proven communication skills