OIG Formula for Success

Arbor Rehabilitation has over 40 years of experience in the healthcare industry. This industry is heavily federally regulated. Through the years Arbor Rehabilitation has become aware of the many pitfalls of solid organizations that took a misstep and ended up needing legal counsel. The Office of Inspector General (OIG) safeguards the Health and Human Services programs (think Medicare/ Medicaid and more) through fighting waste, fraud and abuse. Knowing your organization's risk areas and mitigating those risks is essential to your reputation. Significant fines on top of legal fees can make any missteps erode your bottom line. In healthcare, following the OIG's 7 Steps for an effective compliance program can help keep your reputation squeaky clean and keep your profits in your pocket!

The first component per the OIG is to have clear policies and procedures as well as a code of conduct. As simple as this may seem, updating those policies and codes can be tedious at best. Reviewing your current policies and employee handbooks on a routine basis can be time well spent when you need to demonstrate adherence to your organization's guidelines. In addition, outdated policies can be detrimental in employee relations when relevant standards of practice are not documented and communicated.

The OIG also recommends a designated compliance officer or committee. Having one point person responsible for keeping policies up to date is one benefit. In addition, having a designated person or committee to investigate allegations of wrong doing enables employees to know who to contact should they have concerns. Consistent individuals following up on reported issues improves follow through. Compliance personnel must be objective and be able to independently report findings to the organization's governing body.

Education and training is key to a successful compliance program. Knowledge of corporate policies and standards enables adherence. Updates in regulations, whether on a state / federal or corporate level must be clearly and promptly communicated to staff. Education is to be provided in such a way as for all staff to understand the information.

Per the OIG, all organizations are to have a reporting system for employees to communicate any concerns they have related to the integrity of the organization. This system must have the option for employees to report anonymously. Information must be handled securely and confidentially.

Regulatory adherence must be monitored and audited. This is where some organizations may be challenged to objectively review their practices with a keen eye on current Medicare and Medicaid standards. Systems need to be in place to routinely assess compliance with your industry's and organization's regulations.

The sixth step to an effective compliance program is enforcement. All employees must abide by governing mandates. Disciplinary consequences for non-compliance must be clearly communicated. Enforcement must be consistently provides across all departments.

Finally corrective action is necessary to respond to and prevent future violations. Reviewing where, how and why something went wrong is essential to creating an effective solution.

In light of the many steps and systems needed for compliance in healthcare, Arbor has now developed it's newest branch, Arbor Healthcare Experts. We are using our extensive experience in healthcare to help your organization excel from a compliance perspective. The Centers for Medicare and Medicaid Services (CMS) has resumed vigorous audits after a temporary slow down during the public health emergency. Now that the PHE has ended, will you be ready for scrutiny?