​1. Cultivate a culture of compliance. A culture of compliance needs to be initiated from the top down and must be ingrained into the organization. Owners and management should become familiar with the OIG guidelines for corporate compliance and the current quality assurance process within their own organizations. One way providers can get started is to take the current code of conduct and compliance policies, dust them off, and make them real—make them part of the company’s day-to-day operations. Having the staff review and sign the code of conduct annually will help maintain the desired culture.

2. Appoint a corporate compliance officer. A corporate compliance officer will lead the organization’s compliance program by examining and tracking quality-of-care and financial issues. In a small organization, this officer may have multiple roles, but regardless of size, the compliance officer must be respected throughout the company and be given autonomy by the board of directors to create an internal audit and quality assurance infrastructure that will serve as the backbone of the compliance program.

3. Train staff. A formal and consistent training program is one of the fundamental building blocks of a solid compliance program. Training can reach staff in many forms, including online, e-learning modules; traditional, in-house classes and seminars; or a combination of both. Regardless of the format in which it is presented, training must be monitored and reevaluated on a regular basis for its ability to meet compliance goals.

4. Establish a complaint hotline. Employees, residents, and families need a mechanism to voice their concerns in a nonretaliatory fashion, and, therefore, a formal hotline should be instituted. The hotline number will need to be prominently posted at each facility and monitored by the corporate compliance officer.

5. Check exclusion lists. Prior to hiring or contracting with potential employees and vendors, providers must check OIG’s List of Excluded Individuals and Entities (LEIE, http://exclusions.oig.hhs.gov/), as well as pertinent state-based registries. Once a person is on these lists of exclusions, federal health care programs, including Medicare and Medicaid, will not pay for services furnished by that person.

Source: “The Case for Compliance,” Upstairs Solutions, Skokie, Ill.