... from MPA, your trusted compliance strategist
Supreme Court gives green light to mandatory compliance programs
On June 28, the United States Supreme Court upheld the majority of the Patient Protection and Affordable Care Act. This means that the Act's requirement that all nursing homes have effective compliance programs by March 23, 2013 is here to stay--and quickly approaching.
In a few months, nursing homes will be expected to have operational compliance programs that are effective in preventing criminal and civil health care violations, and promoting quality of care.
MPA has put together a quiz to help you evaluate your compliance status:
Is your compliance program effective?
1) Have all of your employees and directors been trained on compliance within the last 12 months? Do you have the training logs to prove it?
2) Are your surveys free of repeat citations?
3) Do you have a log documenting that all compliance-related complaints were promptly investigated and resolved?
4) Are you confident that every employee file contains documentation of OIG exclusion screen, background check, and professional license verification?
5) Do you have a process for detecting and returning overpayments?
6) Do you have a Compliance Officer and Compliance Committee? Do your employees know who these people are?
7) Is there a way for employees to report non-compliance anonymously (and are all employees aware of how to do this)?
8) Are violations of the Compliance Program disciplined consistently (every time)?
9) Do you conduct regularly scheduled audits of compliance risks?
10) If the OIG walked into your nursing home tomorrow and asked the nearest employee about your compliance program, would the OIG get an informed answer?
If you answered "No" to one or more of these 10 questions, your compliance program is not effective.
There's still time to comply
While it can take several months or even a year to implement an effective compliance program, nursing homes that start now should be able to make significant progress by the deadline. Now is the time to review your compliance efforts, and expand them as needed in order to make your plan effective.
MPA can help
Management Performance Associates can help you implement an effective compliance program. To learn more, visit our website: www.healthcareperformance.com
Margaret Scavotto
General Counsel & Compliance Manager
