Annual Compliance Training Requirements
Written by: J. Paul Spencer, CPC, COC
As a healthcare compliance professional, there have been two constant pieces of advice that I have provided for medical practices:
- If you do not have a compliance program, implement one, and
- Once you implement a compliance program, follow it.
The Office of Inspector General (OIG) has long defined seven fundamental elements of an effective compliance program, with the third of these being the conducting of effective training and education. Due to the ever-changing landscape of all aspects of healthcare compliance (new codes, coverage guidelines, legislative reforms, etc.), it is recommended that any effective compliance plan conduct training and education at least annually.
For any compliance training to be effective, and therefore meet the requirements of your compliance program, it is best to use the remainder of the seven elements to guide training. It is also important to understand that the remaining six elements do not exist against one another in a vacuum. Training on these remaining elements can be thought of in two groups of three elements to facilitate the best level of understanding of the program and its moving parts.
All training should proceed directly from the compliance officer and/or members of the compliance committee. Annual training provides an opportunity to explain the role of the officer and committee. This flows naturally into reinforcing the organization’s effective lines of communication and responding promptly to detected offenses and undertaking corrective action.
In our heavily technology-reliant industry, it sometimes becomes too easy to forget that behind all compliance processes, there are humans fine-tuning, overseeing and responding, keeping all parts of the program moving. Annual training literally puts a name to a face, which provides an opportunity to stress one-on-one communication for the relating of, and response to, compliance concerns in the organization. It is an opportunity to highlight all avenues of communication of concerns, from written and verbal, to either in-person or anonymous reporting.
It is at this point that the remaining elements of a successful compliance plan are presented:
- Internal monitoring and auditing
- Written policies, procedures and standards of conduct
- Disciplinary guidelines and enforcement
The first half of training has focused on internal processes to ensure a proactive compliance program. The second half focuses on standards and processes that assist in protecting the organization from outside influences and threats. Standards of conduct and disciplinary guidelines demonstrate to your employees, insurance payers and audit entities that the organization is dedicated to combatting waste, fraud and abuse within your organization. Annual compliance training presents an opportunity to review these standards and guidelines with your employees. Any changes that have been made since the last training and education session should be highlighted.
Finally, we come to internal monitoring and auditing. Training in this area should focus on the scope of the organization’s monitoring program, as described in the compliance program. Some time should be spent explaining why internal programs are of the size and scope specified in the program. This is also the perfect time to bring forward specific compliance activities and audit targets of outside entities, such as the OIG Work Plan, Recovery Audit Contractors (RAC) and your Medicare Administrative Carrier. Making your team members aware of the external audit landscape provides an opportunity for you as the trainer to place responsibility for compliance in the hands of everyone in the room. This assists in framing compliance as “us vs. them”, rather than the organization versus its own employees.
All employees attending compliance training should sign in to a handwritten log, indicating attendance at the training. At the conclusion of training, each employee, including trainers, should sign an attestation that states that they have attended training, and that they fully understand the training that has been provided.
Take Action Today
Revitalize your annual compliance training program today! Review and update your strategies to ensure every team member is empowered, informed, and aligned with the seven elements of effective compliance. Start strengthening your program now to safeguard your organization against waste, fraud, and abuse.
About the Author:
J. Paul Spencer, CPC, COC
Paul Spencer has over 25 years of experience on the administrative side of healthcare, including six years with health insurance carriers. In his past role as a compliance consultant, Paul has focused on physician education, with an emphasis on documentation improvement for Evaluation & Management and surgical services.
