Developing and Implementing an Effective Compliance Program

1. Developing and Implementing an Effective Compliance Program Mary Sacilotto,BA,CHC Chief Compliance Officer Alliance, Inc.

2. Establishing a Commitment to Compliance • Board of Directors • President/CEO • Chief Compliance Officer • Essential Compliance Staff • Compliance Committees • Legal Counsel

3. Hiring a Compliance Officer • Experienced in management • Trusted and respected • Effective communication skills • Strong leadership skills • Self-confidence • Stamina • Must have direct and regular contact with the Board of Directors

4. Compliance Guidance • Health Care Compliance Association (HCCA) (www.hcca-info.org) • U.S. Federal Sentencing Guidelines • U.S. Department of Health and Human Services (HHS) • Office of the Inspector General (http://oig.hhs.gov/index.html) • Centers for Medicare and Medicaid (http://www.cms.hhs.gov)

5. Seven Elements of an Effective Compliance Program • Written Standards of Conduct • Designate a Chief Compliance Officer & other appropriate bodies – Compliance Committees • Effective Education & Training • Audits and Monitoring • Reporting and Investigating • Appropriate Disciplinary Mechanisms • Response & Prevention

6. Project Management Plan • Create standards for compliance (conduct, conflict of interest, fraud & abuse, disclosure) • Establish a formal relationship for legal compliance referrals • Implement an anonymous hotline as a reporting mechanism • Implement compliance complaint logs • Develop a compliance program training that outlines organizational culture of corporate ethics • Develop educational presentations programs for Board • Establish Compliance Committees – Board and Internal • Implement an ongoing audit schedule • Expedite investigations and remedy alleged misconduct • Review current policies & procedures for compliance • Measure effectiveness of program ( surveys, focus groups, trend analysis)

7. Compliance Work Plan • Develop an annual work plan • OIG work plan • Semi-annual risks assessments • Audits (internal & external) • Regulatory requirements • Seven elements – education, training

8. Establish Compliance Policies • Code of Conduct • Conflict of Interest Policy • Non-Retaliation Policy • Whistleblower Policy • Anonymous Reporting Tool • False Claims Act

9. Championing Compliance • Meet with Program Directors/Managers • Facilitate Risk Assessments • Conduct Mandatory Compliance Training • Attend Staff Meetings • Conduct Focus Groups • Be visible and keep an open door policy • Establish a rapport • Be flexible and keep an open mind

10. Sustaining a Compliance Program • Considered a work in progress • Constantly changes to adapt to the needs of the company • Develop an Annual Work Plan and assess regularly (approved by Board of Directors) • Remain on the cutting edge by taking advantage of conferences and training opportunities • Establish credibility

11. Questions?