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Creating a “Culture of Compliance”

Creating a “Culture of Compliance”. Ben Burton, JD, MBA, RHIA, CHP, CHC. Objectives. What is compliance? History of Compliance programs? Responsibilities of the Compliance Department What is included in most compliance?

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Creating a “Culture of Compliance”

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  1. Creating a “Culture of Compliance” Ben Burton, JD, MBA, RHIA, CHP, CHC

  2. Objectives • What is compliance? • History of Compliance programs? • Responsibilities of the Compliance Department • What is included in most compliance? • Where can I find information on compliance issues related to my organization? • What does it mean to create a “culture of compliance”

  3. Compliance Definition com·pli·ance noun \kəm-ˈplī-ən(t)s\: the act or process of doing what you have been asked or ordered to do : the act or process of complying http://www.merriam-webster.com/dictionary/compliance

  4. Early Corporate Compliance • 1970s Foreign Corrupt Practices Act of 1977 • Security and Exchange Commission investigations • Required maintain and file accurate information with SEC • 1980s and early 90s • Ant kickback • False Claims Act • Stark • 1991 United States Sentencing Commission Federal Sentencing Guidelines • Chapter 8 part B (effective compliance and ethics program) • 2004 and 2010 Amendments

  5. Compliance 1990 to today • HIPAA • Privacy • Security • HITECH (Health Information Technology for Economic and Clinical Health Act) • 1997 Healthcare Compliance Association (HCCA) • Department of Health and Human Services – OIG • New organizations and focus as the profession grows

  6. Compliance Department • Keeps us all on the straight and narrow • External • Legal • Regulatory • Internal • Policies and Procedures

  7. Compliance (Process) • The seven elements • Set rules, • Define who creates the rules, • How to let everyone know about the rules, • Monitor if the rules are being followed, • Allow people to report potential violations of the rules, • Enforce rules, and • Correct risky processes. • Chapter 8 Part B of the Federal Sentencing Guidelines http://www.ussc.gov/Guidelines/2012_Guidelines/Manual_HTML/8b2_1.htm

  8. Rules • Who • BOD • Compliance Officer • What • Address behavior • Protect against non-compliant or risky activity • Why • Need a reason (purpose or policy part of P&P) • “Show me”

  9. Communication • What • Rules • Where to find them • How • Act • Report

  10. Risk Analysis • Key to any compliance program • Sets the environment • Use the OIG work plan • Used to develop an audit plan

  11. Investigation and Remediation • Means to report issues • Method to investigate possible problems • Way to address and correct issues • Compliance programs need to be proactive

  12. Where to start • Seven elements • Health and Human Services • Research other similar organizations • Internet • Call or e-mail

  13. Health and Human Services - OIG

  14. Culture of Compliance • Documents • Program • Policy • Code of Conduct • Communicate • At least annually • The positive as well as the negative • Incorporate Compliance into other departments • HR • QA or QI • RM

  15. References • http://oig.hhs.gov/compliance/ (Compliance page, OIG website, retrieved 7/29/2014) • http://www.ussc.gov/Guidelines/2012_Guidelines/Manual_HTML/8b2_1.htm (2012 Guidelines Manual Chapter 8 – Sentencing of Organizations Part B – Remedying Harm from Criminal Conduct, and Effective Compliance and Ethics Program, retrieved 7/29/2014) • http://www.ecfr.gov/cgi-bin/ECFR?SID=63d8829318e617d5e56b6945890c9973&page=browse (ELECTRONIC CODE OF FEDERAL REGULATIONS retrieved 8/5/2014)

  16. References • http://www.gpo.gov/fdsys/pkg/STATUTE-91/pdf/STATUTE-91-Pg1494.pdf (Foreign Corrupt Practices Act, retrieved 7/29/2014) • http://www.hcca-info.org/AboutHCCA/HCCAOverview/History.aspx (HISTORY OF HCCA: SUPPORTING COMPLIANCE IN HEALTHCARE SINCE 1997, retrieved 8/5/2014) • http://www.acc.com/chapters/gny/upload/report-sentencing-guidelines.pdf (REPORT OF THE AD HOC ADVISORY GROUP ON THE ORGANIZATIONAL SENTENCING GUIDELINES, retrieved 7/29/2014)

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