As a continuation to examining your policies, review for procedures that may relate to them.
- In a 4-page paper, describe the procedures for each of the two compliance plans.
- Break each procedure section into 2 pages each.
- Remember to support your procedures for each of two plans with a total of three research sources (1-2 per procedure), cited at the end in APA format.
- Write your procedures in a way that all employees will understand at a large medical facility where you are the Compliance Officer.
- Remember, you chose two compliance policy plans under the key compliance areas of Compliance Standards, High-Level Responsibility, Education, Communication, Monitoring/Auditing (for Safety), Enforcement/Discipline, and Response/Prevention. (Check them out if you forget! Remember, you may have written about different policies for the two different compliance plans.)
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Introduction:
This paper will describe the procedures for each of the two compliance plans that were chosen under the key compliance areas of Compliance Standards, High-Level Responsibility, Education, Communication, Monitoring/Auditing (for Safety), Enforcement/Discipline, and Response/Prevention. The procedures will be broken down into 2 pages each for a total of 4 pages. The procedures will be written in a way that all employees will understand at a large medical facility where the Compliance Officer is in charge. A total of three research sources (1-2 per procedure) will be used to support the written procedures, and will be cited at the end of the paper in APA format.
Answer:
Compliance Plan 1: Compliance Standards
Procedure 1: Identifying Potential Non-Compliance
Purpose: To identify potential non-compliance before it becomes a problem.
Steps:
1. Conduct thorough risk assessments of all areas within the medical facility on a semi-annual basis. This includes assessing potential risks in operations, billing, coding, and patient care.
2. Develop policies and protocols to address identified risks.
3. Train all employees on the policies and protocols to ensure understanding and adherence.
4. Conduct regular internal audits to ensure compliance with policies and protocols.
5. Report any potential non-compliance to the Compliance Officer immediately.
Sources:
1. Centers for Medicare & Medicaid Services (CMS). (2019). Medicare Learning Network Booklet. Available at https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/MedicaidIntegrityProgram-Part3-ICN907404.pdf
2. National Institute of Standards and Technology (NIST). (2018). Guide for Conducting Risk Assessments. Available at https://csrc.nist.gov/publications/detail/sp/800-30/rev-1/final
Procedure 2: Monitoring Compliance
Purpose: To monitor compliance with all applicable laws and regulations.
Steps:
1. Develop a compliance monitoring plan that outlines policies and procedures for monitoring compliance.
2. Conduct regular audits to ensure compliance with all laws and regulations, including HIPAA and CMS guidelines.
3. Develop corrective action plans and implement corrective actions as necessary.
4. Train all employees on compliance monitoring policies and procedures.
5. Report any non-compliance to the Compliance Officer immediately.
Sources:
1. Office of Inspector General (OIG). (2017). Compliance Program Guidance for Hospitals. Available at https://oig.hhs.gov/compliance/physician-education/02guidance/hospitals.asp
2. American Medical Association (AMA). (2018). HIPAA Compliance. Available at https://www.ama-assn.org/practice-management/hipaa/hipaa-compliance
Compliance Plan 2: Response/Prevention
Procedure 1: Reporting and Investigating Non-Compliance
Purpose: To promote a culture of compliance and prevent non-compliance through prompt reporting and investigation.
Steps:
1. Develop a reporting and investigation policy that outlines procedures for reporting non-compliance and investigating reported incidents.
2. Train all employees on the reporting and investigation policy.
3. Ensure that all reports of non-compliance are investigated promptly and thoroughly.
4. Develop and implement corrective actions to prevent future non-compliance.
5. Report all incidents of non-compliance to the Compliance Officer.
Sources:
1. CMS. (2018). Compliance Program Guidance for Nursing Care Facilities. Available at https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/som107ap_pp_guidelines_ltcf.pdf
2. OIG. (2017). Practical Guidance for Health Care Governing Boards on Compliance Oversight. Available at https://oig.hhs.gov/compliance/compliance-guidance/docs/Practical-Guidance-for-Health-Care-Governing-Boards-on-Compliance-Oversight.pdf
Procedure 2: Response to Non-Compliance
Purpose: To respond to incidents of non-compliance in an appropriate and timely manner.
Steps:
1. Develop a non-compliance response plan that outlines procedures for addressing incidents of non-compliance.
2. Train all employees on the non-compliance response plan.
3. Conduct prompt and thorough investigations of reported incidents of non-compliance.
4. Develop and implement corrective actions to address the incident and prevent future incidents.
5. Report all incidents of non-compliance to the Compliance Officer.
Sources:
1. CMS. (2019). Compliance Program Guidance for Individual and Small Group Physician Practices. Available at https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/Physician_FactSheet_907404_ComplianceProgram.pdf
2. OIG. (2018). Risk Areas Associated with Medical Devices: A 2018 Update. Available at https://oig.hhs.gov/reports-and-publications/semipharmaceutical-risks/wp-content/uploads/2018/07/MedicalDevicesRiskUpdate.pdf
