Complying with Communication Training Demands: Accountability, Fraud, and Competency
Jeannine LeCompte, Compliance Research Specialist
The communication training requirement for Skilled Nursing Facilities (SNF), which must be in place by November 28, 2019, includes specific programs dealing with accountability, fraud, and competency.
Accountability and fraud compliance can be achieved by the following steps:
- A system must be put in place to evaluate the extent to which employees understand their compliance responsibilities, and a policy established regarding sanctions for those employees who don’t complete the required training. Management should be held accountable for ensuring their employees understand the Code of Conduct and compliance-related responsibilities.
- To comply with the accountability prerequisites, a SNF can establish a program that ties meeting compliance objectives to incentives. This can ensure that employees are aware of and understand the organization’s compliance program and their responsibilities under the program. Compliance in this regard can be shown through activities such as a “Compliance Awareness Week,” or other employee involvement activities.
- The SNF must have established specific compliance competencies for members of the Board and all appropriate governing committees.
- The SNF must have an established formal program to orient new Board members and senior leaders to the compliance program and their obligations and responsibilities. This program must include the topics that will be covered, the frequency of training, current industry developments and resources, and provide education on their responsibilities for compliance.
- All performance appraisals and job descriptions must include the requirement for employees to promote compliance.
- Employees at all levels must be able to articulate the compliance/ethics message, and managers must insert compliance messages into meetings and other communications with staff. All compliance information, training, and updates must be made in a manner that is understandable for employees (reading level, languages, case studies, verbal communication). All of this must be documented for later review by inspectors.
- Every senior management and governance-level meeting must have compliance representatives present, and this should also be documented.
Competency compliance can be achieved by the following:
- The SNF must have defined the competencies required for the compliance staff including requirements for certification or other specific skills/expertise.
- The organization must provide focused education to compliance staff members to ensure they are competent in evaluating and investigating issues.
- All compliance staff must maintain their competency by attending appropriate educational sessions. All of this must be documented for later inspection.
