Corporate compliance: framework and implementation

The federal government has created numerous programs to combat fraud and abuse. The government now encourages healthcare facilities to have a corporate compliance program (CCP), a plan that reduces the chances that the facility will violate laws or regulations. A CCP is an organization-wide program comprised of a code of conduct and written policies, internal monitoring and auditing standards, employee training, feedback mechanisms and other features, all designed to prevent and detect violations of governmental laws, regulations and policies. It is a system or method ensuring that employees understand and will comply with laws that apply to what they do every day. Seven factors, based on federal sentencing guidelines, provide the framework for developing a CCP. First, a facility must establish rules that are reasonably capable of reducing criminal conduct. Second, high-level personnel must oversee the compliance effort. Third, a facility must use due care in delegating authority in the compliance initiative. Fourth, standards must be communicated effectively to employees, and fifth, a facility must take reasonable steps to achieve compliance. Sixth, standards must be enforced consistently across the organization and last, standards must be modified or changed for reported concerns, to ensure they are not repeated. PROMINA Health System, Inc. in Atlanta, Ga., designed a program to meet federal guidelines. It started with a self-assessment to define its areas or risk. Next, it created the internal structure and assigned organizational responsibility for running the CCP. PROMINA then developed standards of business and professional conduct, established vehicles of communication and trained employees on the standards. Finally, it continues to develop evidence of the program's effectiveness by monitoring and documenting its compliance activities.