I recently got married, so the early days of marriage have included combining all of our stuff, sorting through what we have double of, deciding what to keep and what to get rid of. I love this type of stuff; purging and cleaning up can be a stress reliever for me. I know, not everyone sees this the same way, but for me it is an important part of life. If we don’t go through our house on a regular basis we begin to have more piled up than we need, forget what we still have, or even see items we should have removed/replaced years ago.
The same is true for your compliance program policies and procedures. As you encounter new situations or new guidance is released by the DOJ, OIG or OCR you may have added to your policies and procedures to stay up to date. But have you checked to see if you have multiple policies or procedures addressing the same item? When we are doing spring cleaning, we often find more charging cords to devices than we even know what to do with, so we clean out what isn’t necessary anymore. It is a good idea to do this with your policies and procedures on a regular basis as well.
Here are a few filters to use during your compliance spring cleaning:
-Are we still using this technology?
-Is there a new technology we use that has no policy?
-Do the compliance procedures match the organizational chart (have any changes been made)?
-Are there any policies or procedures that are redundant?
-Does the policy make sense? Meaning, it is easy for anyone new to the organization to understand.
-Is this a policy that is even necessary anymore because of changes that have been made?
These are only a handful of filtering questions to use as you do your compliance spring cleaning. Routine maintenance of your program’s policies and procedures is essential to an effective program.
Most business leaders get frustrated when employees don’t do the right thing. You shouldn’t have to convince people to do what is right. MCA builds a compliance program and a culture where employees do the right thing, the right way, at the right time so you can focus on taking care of the people you serve.
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Midwest Compliance Associates