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7 Elements for An Effective Compliance Plan


Home Health and Hospice providers should establish an Ethics & Compliance Program to include the following seven elements as per OIG guidance:

1. Implements written compliance program, code of conduct and high-risk policies and procedures. 

TIP: The Code of Conduct should be easy to read and understand, and reflect the values of the organization.

2. Designates a compliance officer and committee.

TIP: The Compliance Committee should include high-level management personnel from the agency’s major functional areas such as clinical, billing, marketing, human resources and financial.

3. Provides effective training and education.

TIP: Agency should provide intermittent specialized training for staff in high-risk areas such as marketing, billing and human resources.

4.  Establishes effective lines of communication. 

TIP: The agency/company should have an anonymous option for reporting compliance concerns or allegations.

5.  Enforces standards through well-publicized disciplinary measures.

TIP: Uniform disciplinary procedures should be in writing and easily accessible to all employees.

6. Conducts effective auditing and monitoring activities for high-risk areas of business.

TIP: The agency/company should annually develop and or update a written auditing and monitoring plan based on high-risk areas.

7. Responds promptly to allegations of non-compliance or wrongdoing.

TIP: The agency should promptly investigate allegations of non-compliance and report and document resolution while mindful of the 60-day rule, if applicable.

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