OIG Tips Series ~ Do you have an off the shelf, or out of the box compliance plan? OIG compliance tips given by Inspector General Dan Levinson at the annual HCCA Compliance Institute are always valued by the compliance officers and professionals in attendance at the keynote speech. This spring at the Compliance Institute in San Diego IG Levinson engaged the audience with a keynote that utilized an array of colorful slides representing “residents” of the San Diego Zoo and Wild Animal Park.
In sharing the slide of a parrot, Levinson cautioned that a parrot will only say what they hear. The analogy was used to identify a potential risk in healthcare compliance of the notion of having an off the shelf solution or compliance plan. He stressed the individuality of each and every compliance plan as it relates to the institution or provider. The Halifax (Florida) case was presented as a situation in which management did not listen to compliance in addressing STARK issues in their compliance plan.
It’s a message that we at OIG always try to underscore whenever we have the opportunity to talk to management around the country in various sectors, both in writing and orally. It really is so significant a flaw for management when compliance officials are not listened to as they identify and say we have an issue, we need to mitigate it, we need to resolve it.
OIG Compliance Tips: Rehab Lessons
Levinson was clear that a compliance plan should not be a cookie cutter or off the shelf. A good basis for a rehab plan, even for a small practice, is starting with the basic risk areas that are known. An annual risk assessment, supplemented by updates throughout the year based upon internal audit results or new identified risks for therapy, is a start a customizing a compliance plan. Of course the real customization comes in the auditing and monitoring plan, as well as the annual compliance training.
Do you have a compliance plan? Has it been customized to your practice as Inspector Dan Levinson suggests? Have you done a risk assessment? Is you auditing and monitoring plan specific to the risks in your practice?