Adopting MedPro Group, Seven Fundamental Steps of a Compliance Plan, create a comprehensive plan that aligns with the following seven steps: Element One: Implementing Written Policies, Procedures, and Standards of Conduct Devise at least 3 healthcare finance related fraud and compliance policies and accompanying procedures. Your policies and procedures MUST… Explain legal requirements so that employees understand their obligations and how to conform their behavior to meet them State your plans on how to encourage managers and employees to report suspected fraud and other improprieties without fear of retaliation Should be made easily available (identify in a written statement where and/or how one can access the above policies and procedure) Element Two: Designating a Compliance Officer and Compliance Committee to Provide Program Oversight Note; this task was completed with your initial hiring as the new CFO. However, you are to develop a 1-2 page job description in order to seek a compliance officer that will report directly to you. Develop the proposed overview of the Compliance Committee that will be chaired by the above compliance officer. Identify the proposed frequency of meetings (simple schedule over a calendar year) (the committee is expected to meet monthly), the preferred number of committee members and the various departments/areas that each member will represent, identify at least six purposes/responsibilities that the committee is expected to carry out and outline the proposed method of communication (during the scheduled monthly meetings and outside of scheduled meetings) Element Three: Using Due Diligence in the Delegation of Authority This task is completed, as you are the delegated person of authority that oversees the proposed healthcare finance, fraud, abuse and compliance program Element Four: Educating Employees and Developing Effective Lines of Communication Note; this task was partially completed with the above Power Point presentation; however let’s prepare take your work to the next level… Develop clear and practical steps that will be taken in order to disseminate information about the organization’s compliance program and its policies and processes Devise a training schedule (identify the frequency of the conducted training’s, identify who will be required to attend) along with an assessment to monitor the effectiveness of the training session. Draft a one-page agenda that outline the proposed topics of discussion that will be covered in the training session As a continuation of Element One, discuss how employees can report suspected fraud. For example, you may establish an anonymous reporting contact number or electronic email reporting system. Draft a generic automated response that an individual will receive after submitting a report. This will include a thank you line as a confirmation. The estimated time for a response and a person or number to contact for further assistance Element Five: Conducting Internal Monitoring and Auditing Discuss the efforts that will be taken to ensure that the financial practices are compliant and adheres to ethical guidelines and standards Outline the process of conducting internal monitoring and auditing practices Design a healthcare fraud, abuse and compliance calendar template that includes the following: Department Regulation/Statute/Law Department Name of the Individual Completing the Calendar Date & Signature Line Actions Steps to Compliance: Steps/Description, Responsibility and Completion Date Standards Section that will be evaluated (this should be included as a column): requirement, deadline/due date, responsible office/department and status Element Six: Enforcing Standards Through Well-Publicized Disciplinary Guidelines Develop a generic outline that addresses the following: Explains who is covered Standards of conduct Discipline and enforcement Reporting (obligations), whistleblower, non-retaliation Create a five (5) Q&A handout for the intent of distributing to employees. Devise questions and answers that are appropriate to healthcare finance, fraud, abuse and compliance Element Seven: Responding Promptly to Detected Offenses and Undertaking Corrective Action Provide a generic response in terms of responding to detected offenses. Create a four (4) step corrective action approach that aligns with your Human Resource (HR) guidelines and standards as it relates to employee disciplinary actions
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