Module 04 Course Project - Writing Compliance Procedures
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Compliance Policies
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Compliance Policies
In the previous project, two compliance plans were developed and a job description developed for safety and compliance manager. However, strength for any compliance programs depends on compliance policy and procedurals which outlines applicable laws, regulations and standards that should be followed to implement developed plans. Compliance policies should be clear and simple to eliminate confusion or difficulties which may be experienced by implementers of compliance plans. Considering there are two compliance plans, to enhance clarity on the developed compliance, each compliance plan would be considered individually constituting two sections for two compliance policies under each compliance plan.
Compliance Plan For Covid protocols
The impact of Covid-19 has been felt in all sectors of economies and health sectors is not exceptional. Even though numerous professionals have been affected by the virus, significant healthcare providers have succumbed to the virus on the line of the duty. According to a study conducted that assess the impact of Covid-19 on the health sector, as of April 2020, countries that reported the significant number of healthcare providers that had succumbed to the virus are Italy with 44%, Iran with 15%, Philippines with 8%, Indonesia with 6%, and China, Spain, U.S each with 4% (Iyengar et al…,2020). Healthcare providers are the first line of defense at high risk of infection because they constantly engage and interact with Covid protocols. Given there is no cure for the virus, hospitals are implementing prevention measures to contain the spread of the virus, protect clients and also its staff. However, it has been noticed that staff members have been violating Covid protocols such as washing hands between patients necessitating the development of a Compliance plan for COVID. In the following two sections, compliance policies for the compliance plan for COVID are outlined.
Section 1: Compliance Standards for COVID Protocols
Healthcare providers should comply with standard precaution practices when treating patients regardless of the nature of diagnosis (Beyamo, Dodicho & Facha, 2019). In the healthcare facility, healthcare workers are at high risk of infection. Covid-19 is an infectious disease which means healthcare workers are at high risk of being exposed to the virus. For example, it is reported that more than 570,000 healthcare personnel had been infected with the virus in America (PAHO, 2020). This underscores need to take standard precaution which constitutes of policies which aimed at reducing the risk of transmitting infection in the healthcare (facility Beyamo et al…, 2019). Standard precautions are not selective to particular diseases because medical personal handles clients with a variety of infections.
To minimize the spread of Covid in the healthcare facility, standard precaution policies entail hand hygiene which requires healthcare providers to wash their hands with soap and water before and after attending to clients, use hand antisepsis and also to apply surgical hand scrub. According to the World Health Organization (2020), hand washing is the most effective way to contain the spread of COVID-19. Therefore, hand hygiene is an integral part of standard precaution that healthcare providers should seek to implement to minimize the spread of the virus.
Protective Personal equipment (PPE) which includes uses of surgical face masks, aprons, goggles and closed boots is another ingredient of standard precaution that should be implemented in the healthcare facility (Beyamo et al…, 2019). To prevent the spread of COVID-19, healthcare providers need to cover key entry points (nose, eye and mouth) which pathways for viral droplets hence the need for healthcare facilities to ensure all healthcare workers have effective PPEs (Hung et al….,2020). Healthcare facilities procure adequate PPEs which are recommended by the ministry of health as one of the standard precaution policies that not only protect healthcare providers but also the patients.
Section 2: Communication Policy on Prevention Information
Communication is a powerful tool which when exhausted, the violation of COVID rules and protocols can be avoided. Lack of information could be the reason for the violation of COVID protocols. Under the communication policy, the safety and compliance manager should provide accurate and timely information on the COVID protocols to the medical staff. Further, safety and compliance officers should deliver the message to the employers on what they need to do to protect their families from contracting the diseases. Communication policy outlines channels of communication to medical staff and visiting clients. A medical facility should seek to ensure it has effective communication systems and structures to pass COVID prevention information.
Billing Compliance Plan
Billing fraudulent cases have been reported severally and control such incidences, Medicaid Fraud Control Unit prosecute healthcare providers that charge people healthcare services that should be provided freely (Flasher & Lamboy-Ruiz, 2019). Auditors need to be furnished latest fraud insights so that when auditing systems and transactions, can easily identify fraudulent billing activities. However, fraudulent billing activities do not only happen in public health facilities but they do happen across the board. This calls for a need for private health care facilities to be extra cautious and institute monitoring programs that can help them detect fraudulent activities.
It is noted that the up coding and misrepresentation of clinical information is rampant with a total value of about $100 billion (Drabiak & Wolfson, 2020). Physicians are using unorthodox methods to make a profit and the amount of money reimbursed in the concerted effort to optimize profit (Drabiak & Wolfson, 2020). This demonstrates the seriousness of fraudulent activities in the health sector which sometimes lead to wrong prescription and treatment to siphon more from the clients.
In the case of the medical facility of our concern, it has been established that medical staff charge clients for application, a cost that already has been paid on the cast. This questions knowledge of the medical staff on the billing system that is applied by the facility whether they have information on the distribution, composition and nature of charges. It is believed that medical staff are not strangers to the billing system and double billing could collusion to fraudulently extort money from the client. It is on this background billing compliance plan has been developed that constitutes two compliance policies outlined in sections three and four as shown below.
Section three: Procedure
The person that undertakes the billing exercise must demonstrate ethical and professional standards. This requires personnel to consistently comply with ethical and professional standards by being honest and fair in charging the clients. Violation of integrity and fairness principles is tantamount to violation of personal responsibility that attracts disciplinary action against the officer.
Medical staff must comply with the billing process and system that has been developed by the healthcare facility. This requires medical staff to familiarize themselves with the billing system, applicable charges for all treatment and treatment procedures, reimbursement programs and inclusive and non-inclusive charges to avoid double charging clients.
Section four: Auditing
The medical facility will recruit an internal auditor that will regularly determine compliance of billing officers with a legal requirement. Further, the internal auditor will monitor transactions in the medical facility to ascertain adherence to the billing compliance plan.
Annually, the medical facility will recruit an external auditor to carry out control and substantive test. The control test establishes whether the facility has enhanced a strong internal control system (Mahaluça et al…, 2019). On the other hand, substantive test checks the accuracy of transactions and whether there is a material error in the financial statement (Mahaluça et al…, 2019). Auditing is an important policy in billing compliance plan for monitoring purposes.
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.
CDC. (2020). COVID-19 Communication Plan for Select Non-healthcare Critical Infrastructure Employers. Retrieved from https://www.cdc.gov/coronavirus/2019-ncov/community/communication-plan.html
Drabiak, K., & Wolfson, J. (2020). What Should Health Care Organizations Do to Reduce Billing Fraud and Abuse?. AMA Journal of Ethics, 22(3), 221-231.
Flasher, R., & Lamboy-Ruiz, M. A. (2019). Impact of enforcement on healthcare billing fraud: Evidence from the USA. Journal of Business Ethics, 1-13.
Hung, O., Lehmann, C., Coonan, T., Murphy, M., & Stewart, R. (2020). Personal protective equipment during the COVID-19 pandemic (Letter #2). Canadian journal of anaesthesia = Journal canadien d'anesthesie, 67(11), 1649–1650. https://doi.org/10.1007/s12630-020-01785-3
Iyengar, K. P., Ish, P., Upadhyaya, G. K., Malhotra, N., Vaishya, R., & Jain, V. K. (2020). COVID-19 and mortality in doctors. Diabetes & metabolic syndrome, 14(6), 1743–1746. https://doi.org/10.1016/j.dsx.2020.09.003
Mahaluça, F., Chissengue, G., Uamba, J., Pereira, I., Mabjaia, E., & Vilanculos, A. (2019). Importance of Applying Statistical Sampling to Increase Confidence in Financial Statements. Int J Account Res, 7(198), 2.
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