Developing and Revising Your Organization’s Code of Conduct
The Code of Conduct (Code) should be a statement of an organization’s guiding principles and standards, and it must be…
Assessing Internal Controls is Critical to Effective Compliance Programs
Compliance Officers are faced with ever-changing laws and regulations and intense scrutiny by regulatory and enforcement agencies. Unfortunately, Compliance Officers…
Tips on Hotline Effectiveness
Employee communication of compliance issues through a hotline is vital to any effective compliance program. The challenge is finding useable…
Evidencing Management’s Healthcare Compliance Commitment
Compliance is a top-down program, beginning with members of the executive leadership. At all levels, they must clearly articulate commitment…
OIG Issues Advisory Opinion on Charitable Pediatric Clinic Providing Cost-Sharing Waivers
The Department of Health and Human Services (HHS) Office of Inspector General (OIG) recently issued an advisory opinion regarding a…
2019: Time for Evidencing Compliance Program Evaluation
The compliance officer, like any program manager, is responsible for the ongoing monitoring of their program. However, compliance officers should…
Developing a Patient-Centered Nursing Home Compliance Program that is 3E (Effective, Efficient, and Economical)
As discussed in the last issue, in less than one year (November 2019) all nursing facilities participating in the Medicare…
Expert Advice Regarding Compliance Risk Assessments
Several national surveys indicate that most health care organizations perform periodic compliance risk assessments, which is a cornerstone for any…
Board Oversight is Critical for an Effective Compliance Program
Gaining interest and support from the Board of Directors (Board) is essential for any compliance program. Boards need to be…
Tips on How to Properly Structure Compliance Policy Documents
Every Department of Health and Human Services (HHS) Office of Inspector General (OIG) compliance document stresses the importance of the…
Effective Compliance for an Independent Charity Patient Assistance Program
Patient assistance programs (PAPs) provide financial assistance to eligible individuals who incur high drug bills. PAP organizations face heightened governmental…
Survey Employees for a Fresh Look at Your Compliance Program
Steve Forman, CPA, has built, managed and assessed over 50 compliance programs. In his experience, a good way to gain…