Article | March 21, 2022

Effective Compliance Plans: When Was the Last Time You Reviewed Yours?

The Current Environment

The emphasis on mandatory compliance programs, ever-changing regulations and heighted scrutiny requires compliance officers to proactively focus on elements that impact all aspects of the organization’s operations, especially the effectiveness of controls (such as billing and coding), regulatory issues (State and Federal regulations such as Stark and Anti-Kickback) corporate culture, compliance training and employee satisfaction.

Approach to Improvements

It has been KHC’s experience that periodic reviews of compliance program elements results in the most effective programs. Effective compliance programs eliminate, reduce or mitigate an organization’s risk, and build awareness of the compliance effort at all levels of the organization. KHC and Client personnel work together as a team to plan and perform the review, resulting in an effort that is cooperative, as well as efficient. KHC professionals have designed, implemented and/or reviewed comprehensive compliance programs at hospitals, physician practices, ASCs and DMEs. The exposure to, and expertise in, such diverse organizational models gives KHC professionals the unique advantage of being able to address the myriad of challenges that exist across the healthcare continuum.

Our Review can be comprehensive or focused exclusively on selected areas.

Some areas we can assist with include:

  • Review of the seven elements of an effective compliance program; identify and prioritize compliance and noncompliance risk.
  • Develop tool(s) for monitoring and reporting areas of compliance risk, especially those identified as high risk.
  • Provide assistance in the development of a Corporate Compliance Work Plan.
  • Improve and develop internal compliance controls and standards.
  • Write and implement necessary policies and procedures for the compliance program and provide operational implementation.
  • Assess the Compliance Committee and Subcommittee structure and areas of responsibility and provide recommendations.
  • Review employee compliance training education.
  • Assess response to reported non-compliance matters.
  • Review physician contracting including employment, directorships and leases.
  • Review coding and documentation compliance.