What is corporate compliance?
In 2010, the Affordable Care Act mandated compliance programs for Medicare and Medicaid providers, such as Elizabethtown Community Hospital.
What began as corporate compliance in regard to large, publicly-traded companies has since carried over into healthcare. Hospitals are also required to have corporate compliance programs in place that indicate the organization’s commitment to operating in a manner consistent with rules and regulations set forth by Medicare and Medicaid.
The purpose of compliance programs is to develop internal controls that promote adherence to applicable federal and state law, and the program requirements of federal, state, and private health plans. The adoption and implementation of voluntary compliance programs significantly advance the prevention of fraud, abuse, and waste in these healthcare plans while at the same time furthering the fundamental mission which is to provide quality care to patients.
According to the OIG, a corporate compliance program should have seven elements:
Written compliance policies, procedures, and standards of conduct;
A compliance officer and compliance committee, responsible for monitoring compliance efforts and enforcing practice standards;
Effective training and education on the compliance policies, procedures, and standards of conduct;
Communication with staff and allow anonymous reporting mechanisms;
Internal monitoring and auditing by performing periodic self-audits;
Standards for employees through well-publicized disciplinary guidelines; and
Prompt response to detected offenses; development of corrective action plans.
Corporate compliance programs are now a mandatory condition of participation – in other words, hospitals are not able to bill Medicare or Medicaid for services provided to patients without a corporate compliance program in effect.