Compliance Program Development and Implementation

As consultants and as Chief Compliance Officers for large integrated health systems and multi-hospital systems, JD HealthCare Partners, LLC has worked extensively with the United States Sentencing Commission Guidelines and the HHS OIG Compliance Program Guidance for various segments of the healthcare industry to develop and implement effective compliance programs. 

Compliance Program Operation and Maintenance

Building the compliance program is only part of the challenge.  JD HealthCare Partners, LLC has extensive experience in operationalizing compliance.  Specifically, the experience of JD HealthCare Partners, LLC is focused on how to incorporate changing laws and regulations into the existing operations of the hospital to minimize disruption and maximize the likelihood of compliance.  Our experience working in hospitals and incorporating new requirements has taught us that successful implementation of compliance initiatives comes not by mandate, but by working with the affected departments to:  (1) Understand current operations and the impact of a change on current operations; (2) Educate the department on the new requirements; and (3) Collaborate on a solution to achieve compliance.

Risk Assessment and Annual Audit Workplans

As part of an effective compliance program, health care organizations must periodically assess compliance risk and develop an audit workplan to address identified risk areas.  JD HealthCare Partners, LLC has extensive experience developing annual audit workplans that address identified risk areas in a manner that is sensitive to the audit resources of the organization.  Even when the risk cannot be quantified, certain preventative audits of typically high-risk areas are prudent to ensure that a process is in place to ensure compliance, the process is being followed, and that there is not any evidence of non-compliance.  

See our RESOURCES page under "Stark Law" for free downloadable resources and materials pertaining to the Stark Law. 

Compliance Program Assessment and Effectiveness Measurement

Periodic assessment of an organization’s compliance program is important to ensure:  (1) The foundational elements remain in place; (2) Auditing and monitoring of specific compliance risk areas is occurring as planned; and (3) The organization can evidence, through objective measures that the compliance program is operating effectively and the organization has established a culture of compliance.  JD HealthCare Partners, LLC relies on its past consulting and Chief Compliance Officer experience to assess compliance programs and develop recommendations for effectiveness.  From a thorough working knowledge of hospital operations, including the many idiosyncrasies that exist within hospitals, JD HealthCare Partners, LLC advises its clients on the elements for evidencing the effectiveness of the compliance program, as well as the practical and successful approach to implement the elements.  

  
Board Education and Training

JD HealthCare Partners, LLC understands that an effective compliance program requires a Board that is educated on compliance and knowledgeable about the operations of the organization’s compliance program.  The Board must know its obligations of oversight and how that obligation is met and, on an on-going basis, must receive sufficient information about the operations of the compliance program to know with certainty that it understands the current state of the compliance program and the potential compliance issues that confront the organization.  JD HealthCare Partners, LLC has extensive experience with educating public and private hospital Boards and the development of quarterly and annual reports on compliance activities that provide a comprehensive review of the operation and function of the organization’s compliance program.  

Responding to Compliance Issues and Investigations

The ability of the Compliance Office to effectively respond to raised issues and concerns is dependent upon the structure of the compliance program and the organization’s commitment to a culture of compliance.  Government contractor audits have put the Compliance Office on the front lines of interaction with regulatory agencies.  JD HealthCare Partners, LLC is able to provide sound, experience-based advice to its clients to provide them with peace of mind knowing that the guidance they received comes from nationally recognized experts in healthcare compliance.

Compliance Program Assistance