Jeannine LeCompte, Compliance Research Specialist
The appointment of a compliance committee is an important step in ensuring that a compliance and ethics program, as mandated by the office of the Inspector General (OIG), is fully implemented in skilled nursing facilities reliant on Medicaid or Medicare funding. The OIG recommends that a compliance committee be established to advise the compliance officer and to assist in the implementation of the compliance program.
When developing an appropriate team of people to serve as the compliance committee, a facility should consider a variety of skills and personality traits that are expected from those in such positions. Appropriate skills would include a background in law, business administration, and nursing. A fine attention to detail, and scrupulous honesty are also vital.
Once a facility chooses the people who will be members of the compliance committee, it should then train those individuals on the policies and procedures of the compliance program, as well as on how to discharge their duties.
The committee’s functions should include:
- Analyzing the legal requirements with which the facility must comply, and specific risk areas;
- Assessing existing policies and procedures that address these risk areas for possible incorporation into the compliance program;
- Working with appropriate departments to develop standards of conduct, and policies and procedures to promote compliance with legal and ethical requirements;
- Recommending and monitoring, in conjunction with the relevant departments, the development of internal systems and controls to carry out the organization’s policies;
- Determining the appropriate strategies and approaches to promote compliance with program requirements and detection of any potential violations, such as through hotlines and other fraud reporting mechanisms;
- Developing a system to solicit, evaluate, and respond to complaints and problems; and
- Monitoring internal and external audits and investigations for the purpose of identifying deficiencies, and implementing corrective action.
The committee should also undertake other functions as the compliance concept becomes part of the overall nursing facility operating structure, culture, and daily routine.
