Will your compliance plan pass the effectiveness test?
A healthcare organization that has a dynamic compliance plan that is regularly reviewed, revised, and followed is more likely to be in compliance with Federal and state laws and regulations. Healthcare financial managers should be guided by the criteria for compliance plans set forth by the Department of Justice and the Office of Inspector General in their "Compliance Program Guidance for Hospitals." An independent audit of the compliance plan is recommended, but a careful internal examination of the plan should be performed before the independent audit takes place. It is important to determine how well the plan is followed, revise the plan if necessary, and document actions taken to fulfill the plan's requirements.