Eli's Hospice Insider

Published on Thu Jan 28, 2010 PDF

An effective compliance plan helps ensure that your hospice conforms to federal and state law, says Michal. The OIG outlines seven fundamental elements for creating your plan:

1.Implementation of written policies, procedures, and standards of conduct.

2.Designation of a compliance officer and compliance committee.

Your plan should include a team approach to addressing compliance issues -- you can't just have one person in charge of compliance, Michal says.

3.Provision of effective training and education. This doesn't mean just initial training for staff, Michal says. Gear training toward the job that each person is doing and make it ongoing, she recommends. If monitoring turns up an area of weakness, make that area should be a subject for more training.

Bottom line: Training staff at the front end, train for staff job duties, and then provide ongoing training as well, Michal says. 4. Development of effective lines of communication. Make sure that staff members have a place to express their concerns about compliance, such as internal or external hotlines, Michal says. Providing a safe way for people to tell you what they think might be a compliance problem, will allow you to investigate. And even if complaints come from folks who may not have a whole lot of credibility in your organization, those complaints still have to be taken seriously, Michal says.

5. Enforcement of standards through well-publicized disciplinary guidelines. These guidelines should be enforced in a fair and consistent manner, Michal says.

6. Conducting of internal monitoring and auditing.

7. Prompt response to detected offenses and development of adequate corrective actions.