Compliance 101: Ch. 2 Seven
Elements to an Effective Compliance
Program Test Questions Fully Solved.
The Seven Essential Elements of an Effective Compliance Program - Answer 1.Standards
(Code) of Conduct/Policies and Procedures
2. Compliance Officer and Compliance Committee (establishing compliance oversight)
3. Education (conducting effective training and education)
4. Monitoring and Auditing
5. Reporting and Investigating (developing effective lines of communication and screening)
6. Enforcement and Discipline (enforcing standards through well-publicized disciplinary
guidelines)
7. Response and Prevention (responding promptly to detected offenses and undertaking
corrective action)
1. Standards (Code) of Conduct/Policies and Procedures (Seven Elements of an Effective
Compliance Program) - Answer - first and foremost, demonstrates the organizations ethical
attitude and its enterprise wide emphasis on compliance with all applicable laws and
regulations.
- for all employees, vendors, contractors, suppliers
- provides a process for proper decision making, for doing the right thing, and behavior
- tailored to the organizations culture, business, and corporate identity
- Disciplinary procedures and penalties should be stated Plainly and clearly written
- Translated into other languages when appropriate
- Consistent with company policies and procedures- Policies and Procedures address areas of
risk (only thing worse than not having a policy, is having a policy and not following it).
- a policy of non-retaliation/non-retribution should be developed and communicated
- policies developed so that staff knows what to do if prevented with a subpoena, search
warrant, or if questioned by a government investigator.
- Stand alone document. Should be included in every general compliance training session.
Every organization needs to assure that Policies and Procedures in the Code of Conduct exist
for: - Answer - Auditing and monitoring- Compliance record retention
- Self disclosure-Regular sanction checks (may be in HR)
- specific areas of risk (conflict of interest, billing, clinical integrated networks, third-party
relationships, etc)
, - Non-Retaliation (may be in HR)
- Stark/Anti-kickback
- HIPAA Privacy and Security
Code of Conduct Purpose: - Answer • To present specific guidelines for employees to follow
• To confirm that all employees comprehend what is required of them
• To provide a process for proper decision making
• To confirm that employees put standards into everyday practice
• To elevate corporate performance in basic business relationship
• To confirm that the organization upholds and supports proper compliance conduct
Code of Conduct: Content Checklist - Answer - demonstrates system wide emphasis on
compliance with all applicable laws and regulations.
- written plainly and concisely so all employees can understand the standards
- translated into other languages
-includes internal and external regulations
- mentions org policies w/out completely restating.
- consistent i/ org policies and procedures.
Code of Conduct and Employees - Answer - all employees must receive, read and understand
that standards.
- a supervisor should explain the standards and answer any questions.
- employees should attest in writing that they have received, read and understand the
standards.
- employee compliance w/ the standards must be enforced through appropriate discipline when
necessary.
- discipline for noncompliance should be stated in the standards.
2. Compliance Officer and Compliance Committee (Seven Elements of an Effective Compliance
Program) - Answer - "To carry out such operational responsibilities, such individuals shall be
given adequate resources, appropriate authority, and direct access to the governing authority of
an appropriate subgroup of the governing authority"
- OIG considers there to be some risk involved in having the compliance officer report to general
counsel or to the CFO
- Compliance Officer should not be council, nor subordinate counsel, for the provider
- the compliance officer is the "focal point" of the compliance program and the compliance
committee advises the Compliance Officer and assists in the establishment of the compliance
program.
Elements to an Effective Compliance
Program Test Questions Fully Solved.
The Seven Essential Elements of an Effective Compliance Program - Answer 1.Standards
(Code) of Conduct/Policies and Procedures
2. Compliance Officer and Compliance Committee (establishing compliance oversight)
3. Education (conducting effective training and education)
4. Monitoring and Auditing
5. Reporting and Investigating (developing effective lines of communication and screening)
6. Enforcement and Discipline (enforcing standards through well-publicized disciplinary
guidelines)
7. Response and Prevention (responding promptly to detected offenses and undertaking
corrective action)
1. Standards (Code) of Conduct/Policies and Procedures (Seven Elements of an Effective
Compliance Program) - Answer - first and foremost, demonstrates the organizations ethical
attitude and its enterprise wide emphasis on compliance with all applicable laws and
regulations.
- for all employees, vendors, contractors, suppliers
- provides a process for proper decision making, for doing the right thing, and behavior
- tailored to the organizations culture, business, and corporate identity
- Disciplinary procedures and penalties should be stated Plainly and clearly written
- Translated into other languages when appropriate
- Consistent with company policies and procedures- Policies and Procedures address areas of
risk (only thing worse than not having a policy, is having a policy and not following it).
- a policy of non-retaliation/non-retribution should be developed and communicated
- policies developed so that staff knows what to do if prevented with a subpoena, search
warrant, or if questioned by a government investigator.
- Stand alone document. Should be included in every general compliance training session.
Every organization needs to assure that Policies and Procedures in the Code of Conduct exist
for: - Answer - Auditing and monitoring- Compliance record retention
- Self disclosure-Regular sanction checks (may be in HR)
- specific areas of risk (conflict of interest, billing, clinical integrated networks, third-party
relationships, etc)
, - Non-Retaliation (may be in HR)
- Stark/Anti-kickback
- HIPAA Privacy and Security
Code of Conduct Purpose: - Answer • To present specific guidelines for employees to follow
• To confirm that all employees comprehend what is required of them
• To provide a process for proper decision making
• To confirm that employees put standards into everyday practice
• To elevate corporate performance in basic business relationship
• To confirm that the organization upholds and supports proper compliance conduct
Code of Conduct: Content Checklist - Answer - demonstrates system wide emphasis on
compliance with all applicable laws and regulations.
- written plainly and concisely so all employees can understand the standards
- translated into other languages
-includes internal and external regulations
- mentions org policies w/out completely restating.
- consistent i/ org policies and procedures.
Code of Conduct and Employees - Answer - all employees must receive, read and understand
that standards.
- a supervisor should explain the standards and answer any questions.
- employees should attest in writing that they have received, read and understand the
standards.
- employee compliance w/ the standards must be enforced through appropriate discipline when
necessary.
- discipline for noncompliance should be stated in the standards.
2. Compliance Officer and Compliance Committee (Seven Elements of an Effective Compliance
Program) - Answer - "To carry out such operational responsibilities, such individuals shall be
given adequate resources, appropriate authority, and direct access to the governing authority of
an appropriate subgroup of the governing authority"
- OIG considers there to be some risk involved in having the compliance officer report to general
counsel or to the CFO
- Compliance Officer should not be council, nor subordinate counsel, for the provider
- the compliance officer is the "focal point" of the compliance program and the compliance
committee advises the Compliance Officer and assists in the establishment of the compliance
program.
