CO-Q Training-Elements 2 and 3

Course overview

Element 2: Compliance Program Administration - This elements module addresses: Maintain a compliance budget. Report Compliance Program activity to the Governing Body/Compliance Committee. Coordinate operational aspects of the total Compliance Program with the Compliance Committee. Coordinate organizational efforts to maintain a Compliance Program. Define the scope of the Compliance Program consistent with current industry standards. Ensure that the Compliance Committee goals and functions are outlined. Evaluate the effectiveness of the Compliance Program on a periodic basis. Ensure the Compliance Committee maintains knowledge of current regulatory changes and interpretation of laws. Ensure the Compliance Officer maintains knowledge of current regulatory changes and interpretation of laws. Ensure the credibility and integrity of the Compliance Program. Ensure the Compliance Committee oversees Compliance Program education. Verify the organization has defined the authority of the Compliance Officer at a high level. Verify the Governing Board understands its responsibility as it relates to the Compliance Program and culture. Ensure that the role of the compliance attorney in the compliance process has been defined (job description). Define the responsibilities, purpose, and function for all compliance staff and all other staff (job descriptions). Ensure compliance risk assessments are developed and conducted periodically. Incorporate relevant aspects of regulatory agencies focus into compliance operations. Ensure the Compliance Committee oversees integration of the Compliance Program into operations. Develop and maintain an annual compliance work plan. Demonstrate independence and objectivity in all aspects of the Compliance Program. Maintain a Compliance Committee and Compliance Officer independent reporting structure directly to the Governing Body. Element 3: Screening and Evaluation of Employees, Physicians, Vendors, and Other Agents: This elements module addresses: Ensure the organization has processes in place to identify and disclose conflicts of interest. Include compliance obligations in all staff job descriptions. Include compliance accountabilities as an element of all staff performance evaluations. Ensure background/sanction checks are conducted in accordance with policies and procedures which reflect applicable rules and laws (e.g., employment, promotions, credentialing). Ensure compliance sensitive exit interviews occur. Monitor government sanction lists for excluded individuals/entities. Verify due diligence is conducted on third parties (e.g., consultants, vendors, acquisitions). Ensure corrective action is taken