ALERT! EVERY OFFICE SHOULD DESIGNATE THEIR COMPLIANCE OFFICER. THIS IS MANDATED RULE AND REMINDER FOR THOSE WHO HAVE NOT DONE SO OR HAVE NOT DONE IN A VERY LONG TIME AS A REFRESHER.
Your office, typically the Owner/Office Manager/HR/FD Supervisor, will be your "Designated Compliance Officer" This Compliance officer must be routed out to all staff in a memo advising of their status and contact information. The Compliance office should meet with the owner at least once a quarter to discuss issues, compliance checks, and new implementation programs.
An effective compliance program requires oversight of the program. Your office or practice needs to establish who will oversee the compliance program as the organizations “watch dog”. A compliance officer and or a compliance committee needs to be put in to place. These employees will report directly to the CEO or other senior management (depending on how the leadership is structured), and are responsible for the compliance program structure and administration.
These employees must be able to demonstrate that they have involvement in and detailed familiarity with the organization’s operational and compliance activities. The Compliance Officer or committee are responsible for “reasonable oversight” of the program which entails:
o Approving Standards of Conduct
o Understanding and administering the compliance program structure
o Being informed about the outcomes of audits and monitoring
o Reporting on compliance enforcement activity
o Reviewing and performing effectiveness assessments of the compliance program
As discussed before, it is important to note that compliance plans are not one size fits all. You will needs to establish a plan that works for you and is specifically designed to meet your individual needs. So, while compliance plans should designate a compliance professional, what that will look like will vary depending on the size and structure of your organization. For a big hospital or drug company, it might be appropriate to have a VP compliance officer with a large full time staff. For a small clinic or solo practitioner physician’s office, we wouldn’t expect you to have full time staffers just working on compliance. It might make more sense to designate one employee to be the compliance officer in addition to other clinical or administrative responsibilities.