Question: Adopting MedPro Group, Seven Fundamental Steps of a Compliance Plan, create a comprehensive plan that aligns with the following seven steps:
• Element One: Implementing Written Policies, Procedures, and Standards of Conduct
• Devise at least 3 healthcare finance related fraud and compliance policies and accompanying procedures. Your policies and procedures MUST...
• Explain legal requirements so that employees understand their obligations and how to conform their behavior to meet them
• State your plans on how to encourage managers and employees to report suspected fraud and other improprieties without fear of retaliation
• Should be made easily available (identify in a written statement where and/or how one can access the above policies and procedure)
• Element Two: Designating a Compliance Officer and Compliance Committee to Provide Program Oversight
• Note; this task was completed with your initial hiring as the new CFO. However, you are to develop a 1-2 page job description in order to seek a compliance officer that will report directly to you.
• Develop the proposed overview of the Compliance Committee that will be chaired by the above compliance officer. Identify the proposed frequency of meetings (simple schedule over a calendar year) (the committee is expected to meet monthly), the preferred number of committee members and the various departments/areas that each member will represent, identify at least six purposes/responsibilities that the committee is expected to carry out and outline the proposed method of communication (during the scheduled monthly meetings and outside of scheduled meetings)
• Element Three: Using Due Diligence in the Delegation of Authority
• This task is completed, as you are the delegated person of authority that oversees the proposed healthcare finance, fraud, abuse and compliance program
• Element Four: Educating Employees and Developing Effective Lines of Communication
• Note; this task was partially completed with the above Power Point presentation; however let's prepare take your work to the next level...
• Develop clear and practical steps that will be taken in order to disseminate information about the organization's compliance program and its policies and processes
• Devise a training schedule (identify the frequency of the conducted training's, identify who will be required to attend) along with an assessment to monitor the effectiveness of the training session. Draft a one-page agenda that outline the proposed topics of discussion that will be covered in the training session
• As a continuation of Element One, discuss how employees can report suspected fraud. For example, you may establish an anonymous reporting contact number or electronic email reporting system. Draft a generic automated response that an individual will receive after submitting a report. This will include a thank you line as a confirmation. The estimated time for a response and a person or number to contact for further assistance
• Element Five: Conducting Internal Monitoring and Auditing
• Discuss the efforts that will be taken to ensure that the financial practices are compliant and adheres to ethical guidelines and standards
• Outline the process of conducting internal monitoring and auditing practices
• Design a healthcare fraud, abuse and compliance calendar template that includes the following:
- Department
- Regulation/Statute/Law
- Department
- Name of the Individual Completing the Calendar
- Date & Signature Line
- Actions Steps to Compliance: Steps/Description, Responsibility and Completion Date
- Standards Section that will be evaluated (this should be included as a column): requirement, deadline/due date, responsible office/department and status
• Element Six: Enforcing Standards Through Well-Publicized Disciplinary Guidelines
• Develop a generic outline that addresses the following:
• Explains who is covered
• Standards of conduct
• Discipline and enforcement
• Reporting (obligations), whistleblower, non-retaliation
• Create a five (5) Q&A handout for the intent of distributing to employees. Devise questions and answers that are appropriate to healthcare finance, fraud, abuse and compliance
• Element Seven: Responding Promptly to Detected Offenses and Undertaking Corrective Action
• Provide a generic response in terms of responding to detected offenses. Create a four (4) step corrective action approach that aligns with your Human Resource (HR) guidelines and standards as it relates to employee disciplinary actions