The Office of Inspector General (OIG) provides healthcare entitites with guidelines to develop and implement Compliance Programs. Listed below are those guidlines.
Seven Elements. The GPRMC Compliance Plan will have the following core elements tailored to fit the work force and the essential duties of the area covered:
1. Written Policies and Procedures- Compliance standards and procedures tailored to the work force and subject matter and reasonably capable of reducing illegal or improper conduct.
2. A Corporate Compliance Officer- The identity of Organizational officers and managers with specific assigned responsibility to implement the Compliance Plan.
3. Education and Training- An assessment of which employees and agents are most affected by the Compliance Plan.
4. A Communications Plan- to effectively communicate the standards and procedures to all such affected employees and agents at appropriate intervals and to document their exposure and familiarity with them. In the case of agents, the Plan may require inclusion of model terms in contracts and certification of familiarity and conformity with standards and procedures.
5. Guidelines to Enforce Policies and Procedures- Guidelines that outline disciplinary actions for failing to comply with GPRMC’s policies and procedures.
6. A System for Monitoring and Evaluating Compliance- This helps ensure the Compliance Plan is being followed. It would include discovery of misconduct, reviewing procedures, and reporting to appropriate authorities.
7. A System for Responding to Concerns- including names and phone numbers for reporting suspected illegal or improper activities.