How to Measure Effectiveness of Your Healthcare Compliance Program

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How to Measure Effectiveness of Your Healthcare
Compliance Program
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• While it is absolutely crucial to have an
  effective healthcare compliance program at place,
  it is also important to measure the success of
  that compliance program, which could be
  difficult.
• The available measures-of-success arent always
  industry-specific.
• However, when there is no specific publication in
  place for your needs, you might be able to rather
  adapt some of the tools and resources mentioned
  here, in order to assess whether your healthcare
  compliance program is effective or not

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Self-Assessment Questionnaire

• You can use a self-assessment questionnaire for
  prescription drug and Medicare Advantage
  healthcare compliance program effectiveness.
• In this questionnaire, you would find twenty-six
  pages of questions that specifically relate to
  various elements of effective healthcare
  compliance programs.

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• For instance, Element II (Governing Body,
  Compliance Committee, Compliance Officer), it
  asks Does the compliance officer at your
  organization has express authority (written or
  oral, preferably in written form) to make the
  in-person reports to the CEO and the Board of
  Directors in the sole discretion of the
  compliance officer?
• This question stated above is probably more
  applicable to all healthcare compliance programs,
  suggests the healthcare lawyer Las Vegas,
  regardless of subsections of the health care
  industry, or other industries too, in fact.

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OIG Supplemental Healthcare Compliance Program
Guidance for Medical Centres and Hospitals

• Most healthcare compliance officers are already
  familiar with various OIG healthcare Compliance
  Program Guidance or CPG documents for the
  different segments of health care industry.
• A complete list could be easily found on the
  official website of OIG. A recent CPG includes
  Supplemental Healthcare Compliance Program for
  the Hospitals.
• CPGs Section III mentions Compliance Program
  Effectiveness for Hospitals.

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• This section follows an approach that is similar
  to that of Medicare Advantage Questionnaire,
  where Medicaid investigations are also mentioned.
  
• Various questions are included as these questions
  relate to the 7 components of effective
  compliance programs.
• You would find a frequency for these assessments
  as well, for instance Hospitals need to
  regularly review implementation execution of
  the elements of their healthcare compliance
  program.

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• Such a review needs to be conducted atleast once
  a year and include a thorough assessment of each
  and every basic elements of the program
  individually, along with the overall success of
  the compliance program.
• While some questions may be specific to
  hospitals, it could be easily adapted to other
  types of organizations and providers.

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• Self-Assessment Form for Compliance Program from
  the NYC Office of Medicaid Inspector-General
• The New York (NY) Law requires the specific
  Medicaid provider(s) to certify their healthcare
  compliance program every year. In order to aid
  the provider in making sure that their healthcare
  compliance program is meeting requirements, a
  self-assessment form is thereby provided. This
  form asks several questions that relates to
  various elements of the compliance program under
  the New York Law. It requires 8 elements of the
  compliance program. Here, the 8th element calls
  specifically for policy of non-retaliation and
  non-intimidation.
• All in all, though there may not be a
  popularly-accepted solution to score compliance
  program effectiveness yet, there surely are
  certain tools to give compliance professionals a
  good enough starting point.

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Thank You
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