Celebrating the Healthcare Compliance Officer
The American Institute of Healthcare Compliance is recognizing healthcare Compliance Officers – hats off to you!
The primary goal of a compliance officer is to mitigate risk. Compliance officers must keep up with new and evolving regulations to ensure their organization is compliant. This involves investigating complaints and conducting internal auditing and monitoring for compliance. Larger health organizations have compliance teams and utilize internal auditors to delegate the auditing and monitoring functions within the organization. Compliance is a complex and difficult job!
Healthcare compliance began as a response to concerns about the quality of healthcare provided by medical practitioners. The compliance profession itself emerged in the 20th Century and has progressed to become a critical part of a healthcare organization’s infrastructure.
Since then, compliance officers have become indispensable to the successful and safe running of a business. Compliance officers are responsible for ensuring that companies and businesses obey regulations and requirements imposed on them. The field has since diversified to fit all kinds of firms and businesses. Compliance officers are expected to have high ethical standards, to be reliable, honest, and effective to promote not only a culture of compliance, but to ensure quality of care and patient safety.
The Office of Inspector General (OIG) began publishing Compliance Program Guidances (CPGs) in the late 1990s. These guides were to be used as voluntary, nonbinding documents to support health care industry stakeholders with the intent that they be used for self-monitoring purposes. Access has been available on the Internet at www.oig.hhs.gov to the public. These include CPGs directed at:
- hospitals;
- home health agencies;
- clinical laboratories;
- third-party medical billing companies;
- the durable medical equipment, prosthetics, orthotics, and supply industry;
- hospices;
- Medicare Advantage (formerly known as Medicare+Choice) organizations;
- nursing facilities;
- physicians;
- ambulance suppliers; and
- pharmaceutical manufacturers.
More recently, on November 6, 2023, the OIG has published a general compliance program guidance (GCPG) with promise to publish industry-sector specific guidances in the near future. On February 21, 2024 the OIG stated that the first two industry segment-specific CPGs (ICPGs) will address Medicare Advantage and nursing facilities. OIG intends to publish these guidance documents in 2024, but as of September 2024, we are still waiting for more ICPG information. According to an OIG statement on their website, for the next two ICPGs, OIG anticipates addressing hospitals and clinical laboratories.
About the GCPG vs ICPGs
The General Compliance Program Guidance (GCPG) is a reference guide for the health care compliance community and other health care stakeholders. The GCPG provides information about relevant Federal laws, compliance program infrastructure, OIG resources, and other information useful to understanding health care compliance. This voluntary guide is a document to be updated over time by the OIG.
The GCPG covers the following topics:
- Health Care Fraud Enforcement and Other Standards: Overview of Certain Federal Laws
- Compliance Program Infrastructure: The Seven Elements
- Written Policies and Procedures
- Compliance Policies and Procedures
- Compliance Leadership and Oversight
- Board Compliance Oversight
- Effective Lines of Communication with the Compliance Officer and Disclosure Programs
- Enforcing Standards: Consequences and Incentives
- Risk Assessment, Auditing, and Monitoring
- Responding to Detected Offenses and Developing Corrective Action Initiatives
- Compliance Program Adaptations for Small and Large Entities
- Other Compliance Considerations
- OIG Resources and Processes
The ICPGs will address the following:
- Standards for different types of providers, suppliers and other participants in the health care industry subsector or ancillary industry sectors
- These guidances will be tailored to fraud and abuse risk areas for each industry subsector
- Outlines compliance measures that participants are expected to take to reduce risk
Free Compliance Resources Offered by AIHC
- Now that most healthcare organizations are implementing or in some way utilizing Artificial Intelligence (AI), compliance oversight to ensure quality of patient care and security of data is required to be compliant.
- The American Institute of Healthcare Compliance (AIHC) offers articles on AI, resources to technology governance, and a 3-Part article series on the Basics of AI, Who Regulates AI and Risk. Click Here to access the AI articles.
- Access the AIHC articles under the category of Corporate Compliance to read about developing topics.
- Webinars – watch recordings of live webinars from the AIHC YouTube Channel:
This Article is Written by the AIHC Education Department. AIHC offers online training w/certification in the field of Corporate Compliance, Internal Forensic Auditing on How to Conduct Internal Investigations and Auditing for Compliance for those requiring more than on-the-job training.
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