We both recently returned from presenting to groups of health care providers on creating and implementing effective compliance programs. Although compliance plans and compliance programs are not new to the health care realm, their importance cannot be understated. Accrediting bodies, payers, auditors and investigating entities expect for providers to have compliance plans in place – and expect them to be followed. Here are a few key points about turning a policy into an effective compliance plan:

• Leaders within your organization must clearly communicate their support of the policy and why it’s important. They also have to put their money where their mouth is, committing resources to carry out the plan and ensure accountability.
• Employees must be educated and trained about the policy. It’s simple: Workers cannot follow a policy they don’t understand. An essential second part of this is ensuring employees stay informed as the policy is updated.
• Regular auditing of compliance is critical, and your organization must define how to measure “compliance” before conducting those audits. Periodic surveys can be a helpful way to keep employees up to speed on what’s expected of them.
• Finally, there must be consequences for noncompliance. Your organization needs to establish who has authority to decide on disciplinary action. You also need to create guidelines to ensure the disciplinary process is applied consistently.

Those are some of the takeaways from our presentation. We thought our readers might appreciate more detail in this handout. In addition, we recommend consulting with counsel for a thorough analysis of your compliance plan.