5 steps to a proactive compliance program

With passage of the Patient Protection and Affordable Care Act, Congress mandated nursing home compliance above and beyond the annual surveys conducted by the Centers for Medicare and Medicaid Services. Effective 2013, a mandatory compliance and ethics program will be required of all healthcare agencies, regardless of size.

So how will skilled nursing facilities bridge the gap from annual survey to daily compliance? That’s the subject of a new white paper provided by Upstairs Solutions and presented by Long-Term Living. “The Case for Compliance” examines how quality of care takes center stage for today’s nursing homes. Included in the paper are the top five steps providers should take to get started with a proactive compliance program. Here’s a summary of Upstairs Solutions’ recommendations:

1. Cultivate a culture of compliance. Become familiar with the Office of the Inspector General’s (OIGs) guidelines for corporate compliance/quality assurance and have staff review and sign a code of conduct annually.


2. Corporate compliance officer. A designated officer must manage the organization’s compliance program by examining and tracking quality of care and financial issues. The officer must create an internal audit and quality assurance infrastructure to serve as the backbone of the compliance program.


3. Training. A formal training program is critical to creating a solid compliance program. Training must be monitored and reevaluated regularly to ensure it meets compliance goals.


4. Complaint hotline. Employees, residents, and families need to voice their concerns without fear of retaliation. A formal hotline should be instituted.


5. Exclusions checks. Prior to hiring or contracting with potential employees and vendors, providers must check the OIG’s List of Excluded Individuals and Entities (LEIE, https://exclusions.oig.hhs.gov/). Federal healthcare programs will not pay for items or services furnished by individuals on this list.

To obtain a copy of the full white paper, “The Case for Compliance,” click here.

Topics: Facility management , Leadership