HEALTH CARE COMPLIANCE 1 (HEALTH INFORMATION MANAGEMENT)

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Chapter_9_-_Complaince_Officer-1.pptx

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

7

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