Developing a healthcare finance fraud, abuse & compliance program

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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