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CHC Study Q&A
Healthcare Compliance Certification (1) Standards Policies & Procedures
| Question | Answer |
|---|---|
| What is the Co.'s Code of Conduct? | Their ethical attitude, emphasis compliance w/ all laws, Applies to all, Tailored to culture & business. Should be plain, concise and in all necessary languages. |
| What is the Co.'s Code of Conduct requirements? | It should be reviewed annually, signed attestation of annual review, training provided, compliance enforcement & consistent, discipline for non compliance, hotline & no retaliation should be listed. |
| Why should a Co. have policies and procedures? | It tells employees how to act (eval. accountability and discipline), improves workflow, bring consistency and clarity to all staff. |
| What is a policy? | A guide or governing principle, rules that govern the organization. |
| What is a procedure? | It defines the implementation of the policy and outlines steps to be taken |
| What contents should a policy include? | Title, policy #, purpose statement, definitions, responsible parties, effective date, review date, effect of non compliance. |
| What are some examples of compliance policies? | Non-retaliation, record retention, conflict of interest, auditing & monitoring, investigations, |
| What is a compliance workplan? | An annual roadmap developed with management, communicated to necessary staff and changed as necessary throughout the year. |
| What are issues to considered for a compliance workplan? | The possibility of having to reschedule planned items, reviewing OIG's workplan & issued identified within same & the Co.'s prior year pending items/investigations (audits, policies, training, items from Risk Assessment) |
| What does the compliance program infrastructure consist of? | BODs, Oversight Committee, Management, Drs., Compliance Office and Staff |
| What impacts the compliance program infrastructure? | Size of Co., Resources (budget, people & training) & scope of program (what are you responsible for) |
| What is the compliance function? | Prevention, detection and resolution of actions/issues. |
| What is the legal function? | advises the Co. on legal and regulatory risks defends the Co. |
| What is the internal audit function? | It provides an objective evaluation of the existing risk and internal controls and framework. |
| What is the HR function? | It manages recruiting, screening, and hiring provides training and development |
| What is the quality improvement function? | It promotes consistent, safe, and high quality practices. |
| When an issues arises, what is the first thing you should do? | Call the legal department first and then investigate in order to keep the privacy so it is not independent discoverable. |
| What are the BODs responsibilities? | To understand the comp program background, to be fully engaged in the oversight of the comp program, Adopt a resolution letter (with outline of duties, commitment to CP and reporting requirements for all compliance issues), to know their responsibility |
| What are the oversight committee responsibility? | The committee is recommended by the OIG, review goals & objectives of comp program, oversee implementation & operations of comp program, review reports,trends & recommendations from CO & annual review & evaluation of comp program. |
| What should the composition of the oversight committee include ? | Chair, Drs., Compliance Officer, BODs, Coding/Billing Expert, Senior Management and Legal Counsel. |
| What are the compliance officers responsibilities? | Should have direct board access, should be a high level individual, Communicator and should have operational responsibility in order to manage daily compliance operations and implementation. |
| What are some characteristics of a compliance officer? | Leadership skills, should have trust & respect from leaders and staff, should have a background in healthcare |
| What should a compliance officer & senior management do? | Provide a written statement of compliance expectations, spend more time with management walk the walk and talk the talk |
| What should a compliance officer and physicians do? | Compliance officer should obtain buy-in, educate that compliance is a necessity, spend one on one time with physicians and train documentation & coding responsibility. |
| What are some techniques to obtain buy in? | Motivation, education, participation and cooperation |
| As best practices how often should policies and procedures be reviewed? | At least annually |
| What is the basic framework of the Co,? | The compliance infrastructure |
| What impacts the Co.'s compliance infrastructure? | Size, financial resources and scope of the compliance program impacts the infrastructure |
| What type of policies and procedures should a Co. implement consistent with a compliance program? | Coding, overpayment, non-retaliation, inter/external compliance audits processes, records retention, conflict of interest, confidentially, privacy, regulatory requirements (EMTALA, CLIA, Labors, Stark, Anti-kick, Research), gifts, waivers co-pay & deduc |
| Step 1 for CP per FSG Standards Policies & Procedures | Exercise due diligence to prevent & detect criminal conduct, promote Co. culture for commitment to compliance, law & CP. Shall establish standards, policies, procedure to detect & prevent criminal conduct. |
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Cecy-1535