INCompliance assists health care clients with determining whether their compliance programs are truly effective in preventing, detecting and addressing a wide array of compliance issues. In addition to compliance audits, assessments, and effectiveness reviews, our attorney-consultants regularly conduct compliance investigations, assist in the development and revision of compliance policies and procedures, and provide training on a wide range of compliance topics.

Building a comprehensive compliance program is the first – and most important – step to achieving true compliance, and the first step is preparing comprehensive, up to date policies and procedures, and implementing them. Whether you do not have written policies and procedures in place, or if your current policies and procedures are outdated, we can help you develop and implement an effective program. Utilizing both the regulatory guidance that is applicable to the health care industry as well as industry benchmarks, we work with our clients to develop and implement policies and procedures that are specific to the needs of the organization, meet or exceed OIG expectations, minimize risk and protect the organization.

In order to test the effectiveness of an existing compliance program, we conduct audits of compliance programs, perform a “gap analysis” to identify areas for improvement or modification and make recommendations to fill those gaps. While the scope and duration of the audit varies from client to client, all of our compliance program audits supply the client with a detailed report of our findings, and actionable, realistic recommendations. In fact, many of our health care clients continue to reference our reports for several years after going through the audit process.

When a health care organization is faced with a potential compliance issue, time is of the essence. We assist our clients with internal investigations of compliance concerns, as well as responding to investigations, whether initiated by a government audit, a subpoena, a search warrant or a False Claims Act lawsuit.

INCompliance assisted a large health system, which includes 8 hospitals, 120 outpatient facilities and more than 14,000 employees, in addressing numerous compliance issues and concerns over a period of several years. According to the organization’s compliance director, INCompliance brings professionalism, expertise, availability and an array of useful contacts across the country to each engagement, making our attorney-consultants an easy partnership choice.

We assisted a children’s hospital in conducting an assessment of their overall compliance program for two separate years. The assessments were based on the OIG’s seven elements of an effective compliance program, and encouraged the hospital to refocus their energy and resources to areas of highest risk. In addition to identifying these specific areas in need of improvement, our assessments helped them elevate the profile of compliance organization-wide.

As part of a compliance program audit, we reviewed of the code of conduct and compliance policies and procedures, interviewed key personnel, and provided a written report with gap analysis and recommendations for new/revised policies and procedures for a large health system. We also provided suggestions for strengthening the compliance program and adopting best practices.

This engagement included review and revision of the code of conduct and compliance policies and procedures; recommendations for new policies and procedures needed to meet the OIG guidelines and best practices; and suggestions for changes to the hospital’s existing procedures for exclusion screening and receiving reports of suspected noncompliance to ensure that open lines of communication were established and maintained as part of the hospital’s compliance program.

We reviewed the compliance program of a regional medical center, which addressed a multitude of areas. The review and recommendations were well-received by the staff and provided a definitive roadmap for the future of their overall compliance program.