Corporate Compliance  -  1.A   

has several new requirements for BH/CYS/OTP.  Perhaps most significant is that now all CARF-accredited organizations are required to implement a policy on corporate compliance.  The standard states:  "An organization in the United States receiving federal funding demonstrates corporate compliance through . . ." 

Due to implementation of the  Affordable Care Act, the standard pertains to all CARF- accredited organizations in the United States.  The only organizations that are exempt

There are other new elements to this standard, to include training of all personnel "on the role of the compliance officer [and] the  organization's ongoing procedures for allegations of fraud, waste, abuse, and other wrongdoing."   

Another new part of the standard is for implementation of internal auditing activities.  According to conversations with CARF managers, this is "more than a billing audit."

of the BH/CYS/OTP Standards Manuals, standard 2.F.2 only pertained to organizations that use seclusion and/or restraint in its programs.  It was also stated that "all organizations must consider" applying the standard.  However, new to the 2014 Standards Manuals is a change in wording so that all organizations must apply 2.F.2 whether or not seclusion and/or restraint are used in the programs. 

Standard 2.F.2 now requires that all direct service or front-line personnel receive documented initial and ongoing competency-based training on 8 topics.  NOTE:  If there is documentation of training for some, but not all relevant personnel, this would be partial conformance and a recommendation would be given during an on-site survey. 

 Contact us to learn how your organization could benefit from an on-site mock survey.

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