What elements should your code of conduct include? - -Tone from the top
-Alignment with the organizations, mission, vision, values, culture, and history
-Brief and easily readable
-Conceptually covers general principles of conduct applicable to all members of the organization
-incorporation of real life examples
-Conceptual approach to use your code of conduct should be inspiring, motivational, and encouraging
Deficit Reduction Act of 2005 (FOR MEDICAID) - Requires entities that receive or make payments
under a state Medicaid plan of at least $5 million to have a compliance program
Compliance program staff needs- - Sufficient resources, investment, enough authority, access to
data and people, diversity of skill set
"The ""New Deal"" of the 1930s - Promoted growth of government/rulemaking
1942 War Labor Board - Wage freeze, fringe benefits up to 5% didn't count, employers started
offering health insurance
1973 health maintenance organization (HMO) Act - $300 million to start up, managed care
organizations; requires many employers to offer HMO coverage to employees
2010-present healthcare regulation - Electronic health record; affordable care act; accountable
care organizations; health care exchange
A code of conduct creates a standard of behavior that aligns all stakeholders to a ______ approach -
Single
Access to the board: - CCO should have direct access to the board and have regular meetings
, After reporting the risk assessment to the board, what comes next? - Corrective action planning
and implementation
Benefits of a compliance program - Employee engagement, continuous process of improvement,
good business practices to identify and prevent risks
Best practices (code of conduct) - -Visually appealing
-looks and feels like the organization with color schemes, logos, phrases, pictures of employees
-Contact information for questions or concerns
-Addresses key topics of interest/risk such as billing integrity, privacy of patient, information, physician,
relations, workplace behavior
-annual attestation of receipt, understanding, and adherence by key stakeholders
-Refer to the code of conduct often when answering questions, addressing issues - use code of conduct
as a resource
Board of directors responsibility: - Knowledgeable about content and operation of compliance
program and program oversight- help set the tone at the top
CCO reports directly to: - CEO
CCO- - Maintains credibility and integrity of the program
Civil Monetary Penalties - Federal agencies were given authority to issue penalties to address
noncompliance
Compliance guidelines incorporate many concepts from the - Defense industry initiative
Compliance programs become mandatory - 1998- Centers for Medicare and Medicaid Services
(CMS) require such organizations to establish a plan for complying with all applicable federal and state
standards