The 8 Required Elements of an Effective Compliance
- Slides: 9
The 8 Required Elements of an Effective Compliance Program What is Corporate Compliance and Why Does OCO Need it? What are the 8 Required Elements? How Does OCO Measure Up? Is OCO ‘Behind the 8 -Ball’ in Any of these Areas? The Role of the Board of Directors
OCO’s Corporate Compliance Program assures that policies & procedures are in place to prevent or reduce the risk of: • • Violating laws and regulations Fraud or abuse Mishandling of Medicaid funds Retaliation against employees who report possible violations
The 8 Required Elements 1. Written policies and procedures 2. Employee responsible for day-to-day compliance operation 3. Training & education of all affected employees and persons 4. Communication lines to the responsible compliance position
The 8 Required Elements 5. Disciplinary policies to encourage good faith participation 6. A system to routinely identify compliance risk areas 7. A system for responding to compliance issues as they arise to include identifying and reporting compliance issues to DOH and OMIG and refunding overpayments 8. A policy of non-intimidation and non-retaliation for good faith participation
How Does OCO Measure Up? • • • Uncovering best practices Process vs. punishment Significant accomplishments to date Certified with NYS Using the 8 Elements & Medicaid Work Plan
Strengths: An Established Program • • • Corporate compliance officer Policies and procedures Reporting and communication Disciplinary / non-retaliation Audits, reviews, reporting and disclosures • Initial training and education
Challenges: Becoming Proactive • Routinely identifying risk areas • Consistent education/training annually for employees and volunteers • Compliance education for contractors/vendors • Compliance knowledge for Board members
The Board’s Role • Review Reports from Board committee & Compliance Officer – Develop compliance knowledge – Be aware, ask questions • Assure unhindered, direct communication • Assure adequate compliance resources
Compliance has Come a Long Way A few years ago, it was like a foreign language. . . Now it is much clearer. . . and well established at OCO!
