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8930 SW Gemini Drive, Beaverton, OR 97008.

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Last Updated on:
07/09/08

 

Draft OIG Compliance Program Guidance for Nursing Facilities

The Office of Inspector General (OIG) published draft Compliance Program guidance for nursing facilities in the October 29, 1999 Federal Register.  The OIG believes that a comprehensive compliance program will reduce fraud and abuse and, therefore, the costs of healthcare.  The seven components recommended are:

  1. The development and distribution of written standards of conduct, as well as written policies, procedures and protocols that promote the nursing facility's commitment to compliance and address specific areas of potential fraud and abuse, such as claims development and submission processes, quality of care issues facing residents, and financial arrangements with physicians and outside contractors that may affect the health care provided to beneficiaries.

  2. The designation of a compliance officer and other appropriate bodies charged with the responsibility for developing, operating and monitoring the compliance program, and who reports directly to the owner(s), governing body and/or CEO.

  3. The development and implementation of regular, effective education and training programs for all affected employees.

  4. The creation and maintenance of an effective line of communication between the compliance officer and all employees, including a process, such as a hotline or other reporting system, to receive complaints, and the adoption of procedures to protect the anonymity of complainants and to protect whistle blowers from retaliation.

  5. The use of audits and/or other risk evaluation techniques to monitor compliance, identify problem areas, and assist in the reduction of identified problems.

  6. The development of policies and procedures addressing the non-employment or retention of excluded individuals or entities; and the enforcement of appropriate disciplinary action against employees or contractors who have violated corporate or compliance policies and procedures, applicable statutes, regulations, or Federal, State, or private payer health care program requirements.

  7. The development of policies and procedures with respect to the investigation of identified systematic problems.

Hansen, Hunter & Company has two RNs on staff (Joy Morrow and Louise Larson) to help with items 3 (regular education programs) and 5 (the use of audits).  Please contact Jeff Moore if you would like further information on these services. 

   


Hansen, Hunter & Company, P.C.
8930 SW Gemini Drive, Beaverton, OR 97008 | Office 503-244-2134 | Toll Free 800-547-3159 | Fax 503-244-9754

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