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This area deals with identifying and interpreting the impact of government regulations and law on the organization; identifying the need for and working with others to develop new regulations and laws; investigating, monitoring, documenting, and enforcing existing statutes; and maintaining communication and cooperation with both public and private organizations.
Corporate Compliance
Posted by: Rebecca Troyer on June 26, 2011 at 9:49PM EST

We are a relatively small privately held company and are still learning as we grow. We do not have a corporate compliance program and I am wondering what level of priority this needs to be in the large scheme of things. I believe we do a lot of the items mentioned but nothing is formalized.

I am definitely going to be checking out several of the references Sarah Fontenot referred to. Personally, I found this week particularly interesting.

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(8) Comments
Posted by: Dane Wheeler on July 1, 2011 4:06PM EST
It is very important since it sets a good tone that you business operates ethically. It should be a priority if you bill government health care programs.

Posted by: Emilie Keene on July 10, 2011 7:47PM EST
We are a very small freestanding ambulatory surgery center and our Corporate Compliance Program (CCP) is very small, but to the point. We had our attorney draft the CCP for us. I, the Administrator, serve as the Corporate Compliance Officer. It is my responsibility to educate each employee on the CCP upon hire and annually thereafter and to reinforce it's practices. I believe a CCP is absolutely necessary for any organization, but there's no limit to how big or small the program be; just as long as it's effective.

Posted by: Joseph Brooks on July 15, 2011 9:48PM EST
I agree with Dane that a compliance program definitely has to be priority. As you grow, its important to build the framework around everything you do. It may seem time-consuming now, but making sure you set the right tone today could save you a lot of money and headache later.

Posted by: Stephanie Atkins-Guidry on October 27, 2011 7:33PM EST
A Corporate Compliance Program is key and should be taken very seriously. I have known of two organizations where the OIG came in locked the doors and arrested everyone on site. Your committe should have some legal oversite to assure all the bases have been covered. Typically people don't set out to do wrong but unfortunately they find themselves in something they could never image.

Posted by: Paul Fiore on October 30, 2011 7:22PM EST
I agree that this is a critical component of health care operations. It also provides the guiding set of principles for ethical behavior that help employees understand boundries on behavior and conduct.

Posted by: Mo Sheldon on November 1, 2011 1:41PM EST
I agree with the comments above and might add that since we, as leaders, don't have all the detailed knowledge of what goes on, it helps to set the tone and we can learn a lot from an effective compliance committee. By our asking the questions, we hopefully create an environment/culture of compliance and the behaviors it would foster.

Posted by: Glenda Byrd on November 2, 2011 10:03PM EST
In order to ensure you comply with federal regulations, I feel it is very important to have a written well defined corporate compliance program/plan. You also need a steering committee to oversee adherence to the plan. Our organization has a robust program that includes audits, monitoring and implementatiion of action plans as applicable.

Posted by: Christopher Lee on November 29, 2011 3:08PM EST
As others have said, this should be very high priority. Having no program leaves you with no way of identifying and addressing issues and can suggest to outside agencies that the organization is not serious about compliance. I think a good place to start with a compliance plan is by pulling together a small group to review the annual OIG plan, determine which pieces are applicable to your facility, and do some follow up spot checks to see if you're at risk. It doesn't have to be super complicated, but it definitely should be done.