The Department of Health and Human Services and its Office of the Inspector General (OIG) now strongly encourage all health-care providers to implement effective compliance programs. As a commitment to compliance, the OIG has posted recommendations in the form of Compliance Program Guidance for Hospitals. These guidelines were actually developed by United States Sentencing Commission (USSC) in 1991 and are listed in the Federal Sentencing Guidelines, Ch.8. The USSC developed the Guidelines to promote consistent treatment of individuals and organizations convicted of federal crimes, including fines and restitution, imprisonment and probation or exclusion from participation in various federally funded programs. VUMC uses these guidelines which includes seven fundamental elements of an effective compliance program:
Because healthcare has become so complex in recent years, the industry is under constant scrutiny. Having an effective compliance program in place helps to avoid or minimize legal or regulatory penalties and potential civil litigations. VUMC’s Compliance Program promotes ethical conduct and is designed to establish a culture within VUMC that promotes prevention, detection and resolution of conduct that does not conform to Federal and State law, and Federal, State and private payor health care program requirements, as well as the hospital’s ethical and business policies.