Written By Jennifer Kennedy
In the realm of home-based healthcare, the distinction between good and great care is often defined by the role of compliance. This invisible backbone extends beyond immediate healthcare services, forming a critical framework that upholds every action and procedure to the highest standards of legal and ethical conduct. Healthcare compliance and quality are also closely connected in the healthcare continuum, as both play crucial roles in ensuring the delivery of safe, effective, and ethical healthcare services.
Healthcare compliance programs are structured initiatives and processes implemented by organizations to ensure adherence to laws, regulations, and industry standards. These programs are crucial for promoting ethical practices, protecting patient rights, preventing fraud and abuse, and maintaining the overall integrity of healthcare operations. While incorporating a compliance program in home-based care is a voluntary decision, it is increasingly recommended as a best practice in today’s evolving healthcare landscape. Recognizing their significance, the Office of Inspector General (OIG) for the U.S. Department of Health and Human Services (HHS) recommends the implementation of a comprehensive healthcare compliance program to prevent fraud, waste, and abuse in the healthcare industry.
Beginning in 1998, the OIG implemented a major initiative to engage the private health care community in preventing the submission of erroneous claims and in combating fraud and abuse in Federal health care programs through voluntary compliance efforts. As part of that initiative, the OIG developed a series of Compliance Program Guidances (CPGs) directed at the following provider types that CHAP currently accredits:
The OIG has outlined seven key components that should be part of a quality effective and successful compliance program:
- Implementing written policies, procedures & standards of conduct.
- Designating a compliance officer and compliance committee
- Conducting effective training and education
- Developing effective lines of communication
- Conducting internal monitoring and auditing
- Enforcing standards through well-publicized disciplinary guidelines
- Responding promptly to detected offenses and undertaking corrective action.
These components collectively contribute to the establishment of a robust healthcare compliance program, helping organizations to identify and address potential issues before they escalate and ensuring adherence to legal and ethical standards in the healthcare industry.
A Culture of Compliance
Compliance is not an event. It needs to be a part of the culture of an organization and weaved into everyday practice. Therefore, it is a collective responsibility of all teams to uphold compliance standards. The OIG offers practical tips to foster this culture:
- Make compliance plans a priority now.
- Know your fraud and abuse risk areas.
- Manage your financial relationships.
- Remember, just because your competitor is doing something doesn’t mean you can or should. Call 1-800-HHS-TIPS to report suspect practices.
CHAP’s Vision for Compliance: The Road Ahead
In the past decade, there has been an increase in healthcare fraud, abuse, and waste amongst a variety of provider types, including home-based care. This increase has led to increased oversight from the federal government in the form of new regulations, intense claims review, and program audits. Now, more than ever, CHAP feels this is the right time to incorporate compliance program standards in our standards of excellence for home health, hospice, home infusion therapy, DMEPOS, pharmacy, and home care. Set to launch in mid-2024, these standards will provide time for providers to integrate them into their operations. CHAP will share the standards and their location in our standards of excellence for each provider type in early January 2024. The addition of compliance program standards of practice will assist CHAP provider partners in detecting and preventing fraud, waste, or abuse in their organization, which leads to ethical quality care. We will also offer compliance program education and resources in 2024 to help organizations ramp up their implementation. Please watch CHAP communication carefully to remain updated.
HHS Office of the Inspector General. (2023, Apr 24). Modernization of compliance program guidance documents. Retrieved from https://www.govinfo.gov/content/pkg/FR-2023-04-25/pdf/2023-08326.pdf
HHS Office of the Inspector General. (2023, Nov). General compliance program guidance. Retrieved from https://oig.hhs.gov/compliance/general-compliance-program-guidance/
HHS Office of the Inspector General. (n.d.). Health care compliance program tips. Retrieved from https://oig.hhs.gov/documents/provider-compliance-training/945/Compliance101tips508.pdf