Compliance program paper
MHA/508
Compliance program paper
| Questions | Grandview Hospital | St. Vincent Hospital |
| How internal monitoring and auditing is conducted | “monitoring internal and external audits and investigations for the Purpose of identifying deficiencies, and implementing corrective action.” (Snouffer,2000, p.6) | “All results of assessment, monitoring and audit activity associated with the CRP Plan will be reported directly to the CRO on a real time basis. The CRP Committee and the CEO will receive summary reports. The CRO will report unusual results or those requiring follow up to the respective Board (s) through the Audit Committee. “(Rich, 2009, p.3) |
| How compliance and practice standards are implemented | “A documented practice of refunding of overpayments and self-disclosing incidents of noncompliance with Federal and private payer health care program requirements is powerful evidence of a meaningful compliance effort.” (Snouffer,2000, p.4) | “The CRP will focus on business and professional standards of conduct, compliance with federal, state and local laws, promotion of good corporate citizenship, Prevention and early detection of misconduct, and identification/prioritization of high risk areas and communication/ education regarding corporate responsibility.” (Rich, 2009, p.6) |
| The designated compliance officer (or person designated to be the contact for compliance matters), who that person reports to, and their relationship to the organization’s governing board | “Regardless of the means that a provider uses, whether it is telephone hotline, email, or suggestion boxes, employees should seek clarification from compliance staff in the event of any confusion or Question dealing with compliance policies, practices, or procedures.” (Snouffer,2000, p.12) | “Reporting corrective actions to the government contractor on a voluntary disclosure Basis when deemed appropriate by the CRO after consultation with the Legal Counsel.” (Rich, 2009, p.12) |
| How employees are trained and educated to model compliant behaviors | “Compliance is a dynamic process that helps to ensure that nursing facilities and other health care providers are better able to fulfill their commitment to ethical behavior, as well as meet the changes and challenges being placed upon them by Congress and private insurers.” (Snouffer,2000, p.12) | “means the principles of associate behavior that promote Corporate responsibility. They are described in Ascension Health Policy 14, Corporate Responsibility and Conflicts of Interest.”(Rich, 2009, p.13) |
| How violations or offenses are detected, reported, and corrected | “participating with facility’s counsel in the appropriate reporting of self-discovered violations of program requirements; and continuing the momentum of the Compliance program after the initial years of implementation. The compliance officer must have the authority to review all documents and other information that are relevant to compliance activities, including, but not limited to, medical and billing records, And documents concerning the marketing efforts of the nursing facility and its arrangements with other health care providers, including physicians and independent contractors.” (Snouffer,2000, p.11) | “In order for the CRP to effectively serve its purpose, reasonable steps must be taken to appropriately respond appropriately to any offense or problem detected or reported and to prevent future similar offenses or problems.” (Rich, 2009, p.13) |
| How lines of communication with employees is developed | “An open line of communication between the compliance officer and a Provider’s employees is equally important to the success of a compliance program. In today’s intensive regulatory environment, the OIG believes that a provider cannot possibly have an effective compliance program if it does not receive feedback from its employees regarding Compliance matters.” (Snouffer,2000, p.11) | “Associates will be required to attend or complete via an online learning system a minimum number of mandatory educational sessions each year, as determined by the CRO and the CRP Committee. Publications and other forms of written communication will be used to Support the program tenets and principles.” (Rich, 2009, p.13) |
| How disciplinary standards are enforced | “The consequences of noncompliance should be consistently applied and Enforced, in order for the disciplinary policy to have the required deterrent effect. All levels of employees should be potentially subject to the same types of disciplinary action for the commission of similar offenses, because the Commitment to compliance applies to all personnel within a nursing facility.” (Snouffer, 2000, p.6) | “Determining appropriate disciplinary actions as required by human resources’ Positive Redirection policies.” (Rich, 2009, p.13) |
Executive Summary
In the chart stated above I have chosen two of the most outstanding facilities in Birmingham, Al St. Vincent hospital and Grandview hospital. Hypothetically, the studies have shown that St. Vincent Internal monitoring normally report straight to the CRO proceeding through different stint source. The CRP Committee and the CEO always obtain rapid report. The CRO always report uncommon results or for the ones that require follow up to the respective boards through the Audit Committee. Grandview on the other hand instead of reporting to the CRO they normally investigate for further purpose for identifying deficiencies, and implementing corrective their action. Studies have shown that it would be easier for St. Vincent to reach leadership positions. In recent years CRP normally focus its attention proceeding business and qualified principles of demeanor, compliance with either federal, state or local laws in leadership style. But an insufficient of these studies has focused its attention on how violations and offenses are reported and documented correctly.
To address this issue both facilities have different programs for individuals that seek help and a health care program that remains known as a commanding suggestion of a meaningful compliance exertion. We have set to learn that whatever the provider decide to use, rather it is a telephone hotline, personal cellular device, email, or recommendation box, team members must always ask for an explanation from the compliance staff in the occasion of any misperception or questions dealing with compliance policies, practices, or procedures. It is important for employees to report curative activities to the government contractor on a voluntary disclosure basis after considering the suitable by the CRO after discussing it with the Legal Counsel. Based on personal interactions with different individuals employees are trained and educated on how to handle compliant behaviors. Employees are trained through a process called compliance. Which is basically described as a self-motivated method which assist to certify that nursing facilities and additional health care employees are able to accomplish their obligation to ethical behavior, as well as encounter different changes and challenges that are being placed upon them by congress and secluded guarantors.
While the willingness to sacrifice communication in order to meet the companies goal is the tendency that was shared by leaders and employees. “The consequences of noncompliance should be consistently applied and enforced, in order for the disciplinary policy to have the required deterrent effect. All levels of employees should be potentially subject to the same types of disciplinary action for the commission of similar offenses, because the commitment to compliance applies to all personnel within a nursing facility” (Snouffer, 2000, p.6). I can convince that communication would be the best to adopt for each program. Communication at a work facility is extremely important. Communication allows the employees to be productive and function effectively.
In today’s society it is mandatory that employees attend or widespread through a connected learning system and the slightest quantity of mandatory educational throughout the years, publication and other sort of communication are used to sustenance each sequencer creeds and moralities. As stated in the previous research has shown that work facilities misconduct declines when leaders are effective in communicating values, and that the violations and risks fall within the company when the manager focus on equality.
Reference
Rich, Y, (2009) St. Vincent’s Health System Corporate Responsibility Plan Retrieve from http://www.stvhs.com/forms/CRPPlan2009.pdf (St. Vincent)
Snouffer, A (2000) Office of Federal Advisory Committee Policy. Retrieve from https://oig.hhs.gov/authorities/docs/cpgnf.pdf (Grandview)
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