Discover the benefits of internal communication and self-assessments
by Neil Caesar

We demand an answer to the question, “Why should 
I bother with a compliance program?”

Too many home care companies do not have a useful compliance program in place. These companies have decided—actively or passively—that a compliance program’s benefits are not worth its costs. They have waited as long as possible to implement as little compliance as possible into their daily operations, and this decision is largely shortsighted.

A compliance program can produce ongoing, and often immediate, benefits for a home care company. We have discussed several ways an effective compliance program can help a home care company avoid problems with the government regulations and increase reimbursement. Most recently, we explored how an effective compliance program can create efficient structures for the general dissemination of information within the company, and further encourage effective personnel feedback.

We continue our discussion of compliance program benefits by examining how compliance can improve efficiency and employee morale within a company. These are benefits that can help a home care company nurture and engage a more loyal and savvy workforce.

Internal communication is key to the effectiveness of a home care company’s compliance program. An owner must use the company’s communication system to benefit from its information flow. An effective compliance program must demonstrate to personnel that the home care company truly intends to learn and follow the rules correctly.

The company and its compliance program must demonstrate that it intends to follow through on regulations, and investigate possible violations of law and organizational rules. Through consistent communication from management to its employees about its compliance efforts, this goal can be achieved.

Management must also convey repeated examples that demonstrate how it will evaluate and teach its rules to employees, and express that it visibly intends to fix problems and answer questions.

An effective compliance program must establish procedures that encourage personnel to communicate concerns about violations or other problems. By creating helpful ways to accurately report problems, or merely the possibility of a problem, management can reward those who come forward by demonstrating a strong non-retaliation policy.

These components demonstrate the company’s visible commitment to an overall corporate culture of compliance. They communicate to personnel that the company welcomes productive feedback from its staff members, and that it values their opinions. These are significant benefits from an employee’s perspective.

At its core, a compliance program is an internal communication system—for reimbursement and fraud rules, for HIPAA or for anything else included in a company’s program. This internal communications system demonstrates that ongoing, effective internal communication is important to the company.

A progressive home care company can utilize internal communication protocols in its compliance program as the foundation for improvement to its other policies. Many home care companies now seek 
to incorporate team building and problem solving into their management and operational structures.

An effective compliance program includes a system to monitor and audit continued compliance, and this system can be used for internal self-assessment.

Internal monitoring/auditing is essential to compliance. It enables the system to engage in ongoing self-assessment, to continue compliance with policies and procedures and to continue effectiveness of its internal compliance safeguards.

A well-run organization should have internal monitoring and auditing functions that go far beyond regulatory compliance issues. Subjects to consider include control systems functionality, revenue collections and timely deposits, utilization systems functionality, internal problems not involving regulatory compliance, reporting of non-compliance problems, failure to report non-compliance problems or investigation process and timeline for problem resolution.

Organizations can benefit from the use of internal monitoring and auditing in circumstances and functions outside of regulatory compliance issues.