In this week of our blog series on the 7 elements of an effective compliance program, we will review the importance of developing effective lines of communication. Per the Federal Register Vol. 65, No. 52, compliance programs should include “the creation and maintenance of an effective line of communication between the compliance officer and all employees….”
The Office of Inspector General describes open communication as a “part of organizational culture and internal mechanisms for reporting instances of potential fraud and abuse.” In order for compliance programs to be effective, employees must be able to voice their concerns and/or report on issues of non-compliance. It's important to note that communication in an organization should go both ways—from employees to management and management to employees. Communication between the compliance officer and staff is also of utmost importance. Compliance officers are tasked with the responsibility of setting communication standards and keeping staff informed of issues as they arise.
As outlined in the Federal Register, establishing open lines of communication involves:
- The establishment of an open door policy where staff feel free to communicate their concerns to the compliance officer,
- The implementation of a 24/7 hotline for reporting concerns of fraud and abuse,
- The assurance of confidentiality and anonymity,
- Specialized staff who are trained in investigating reported issues of compliance,
- The logging and tracking of all reported complaints and concerns of fraud and abuse,
- Conducting thorough investigations, and
- Prompt feedback and follow-up with the individual reporting.
Standard 4: Developing Effective Lines of Communication
Communication is one of the key functions of a compliance officer and is essential to the planning, coordination and implementation of a compliance program. In smaller nursing facilities, compliance officers may need to lean on the support of others within the organization. As recorded in the Federal Register,
the compliance officer may need the payment specialist to help with billing issues, the director of nursing to address quality of care issues, etc. At the same time, the compliance officer must retain the integrity and objectivity not to compromise the program in deference to one or more disciplines or departments.
Therefore, it is a nursing facility's responsibility—along with the compliance officer—to ensure that all instances of fraud and abuse are promptly addressed and that investigations are being carried out in an equitable manner.
Why is Establishing Effective Lines of Communication Important?
Effective lines of communication allow for quick feedback, thus allowing the problem to be easily corrected. When efforts are coordinated, effective communication allows for a wider and deeper spread of the message. Remember, to cater your communication style to the employee. For instance, communicating with those in management-level positions may be different than the way you communicate with non-senior level employees—the same goes for new hires. The communication style should be targeted and easily understood by those on the receiving end.
Equally important is the method of communication. Earlier in the article we mentioned the use of a 24/7 hotline which should be accessible not only by staff but patients as well. Other effective forms of communication can include brochures, posters, guides, and infographics. Webinars and teleconferences also serve as effective ways of broadening the reach of your message.Regardless of the methods implemented to encourage two-way communication at your facility, always remember there should never be retaliatory action against an employee for voicing his or her concerns. To eliminate the fear of retaliation, employees should always be made aware of this.
Watch our video on the seven elements of an effective compliance program and join us weekly in this series as we will discuss each of the seven elements in greater detail, along with implementation recommendations.
Don't forget, HHS-OIG encourages providers to seek help and support as needed from outside experts in billing and coding, legal counsel knowledgeable in fraud and abuse laws, and the comprehensive resources available on HHS-OIG’s website.
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