Compliance Plan
Compliance Plan
The first step of in completing your course project is to choose two compliance plans from the list of compliance violation areas below.
1.Clinical staff members are not washing their hands between patients.
2.Employee attacks patients while under the influences of narcotics.
After you choose two areas (only two!), write a paragraph about each one to present to your faculty member. In each paragraph, explain why you believe the chosen area represents key issues in compliance and why you want to develop a compliance plan for this area. (1 page total) Compliance Plan
ORDER A PLAGIARISM – FREE PAPER NOW
Overview
At ProMedica Health System, Inc. and its subsidiaries (“ProMedica”), we are proud of the values that
drive our success. These values shape an environment and culture that nurtures the highest standards
in business ethics and personal integrity. These same ethics and values are displayed in our
commitment to excellence in the services we provide. We have reached an exemplary level of
corporate citizenship that is a benchmark within health care. It is imperative that as individuals we
understand and adhere to these principles and values to protect ProMedica’s integrity and welfare. To
that end, ProMedica has established a Corporate Compliance Plan (“the Plan”) that outlines our ethical
commitment via our Standards of Conduct as well as our legal and regulatory requirements for select
issues covered under the Plan. Healthcare is one of the most highly regulated industries in the country
and there are numerous laws and regulations not addressed herein. That does not mean they are not
important to ProMedica, but that they are addressed elsewhere within the organization. Compliance Plan
Why do we need a Compliance Plan?
The most important reason for implementing a Compliance Plan is simply because it is the right thing to
do. As noted above, we operate in one of the most highly regulated industries in the world. These
regulations change frequently and come from numerous sources. Ensuring that we remain in
compliance requires a team effort and a mechanism for inquiries/reporting, investigating, and resolving
potential issues. It is the intent of the compliance plan to facilitate that process. We also consider
compliance with regulations to be a subset of our objective of maintaining the highest standards of
moral and ethical conduct. Everyone in the organization has a role in that objective and an affirmative
duty to report suspected non-compliance with our standards.
In addition, failure to comply with governmental regulations can result in significant civil and/or criminal
penalties for the organization and potentially its employees, officers, directors and agents as well. The
severity of the penalties assessed is not necessarily dependent on the dollar value of the disputed issue,
or the position of the person within the organization where the noncompliance occurred. For example,
civil penalties under the False Claims Act can include fines of up to $11,000 per each “false claim” Compliance Plan
submitted, and more importantly, the loss of certification to serve Medicare and Medicaid patients. The
presence of an effective compliance plan helps to identify potential issues, aids in mitigating risk, and
provides a defense if we were to be challenged regarding any of our areas of operation. It may also
serve to significantly reduce potential civil and/or criminal penalties.
What is covered by our Compliance Plan?
Although it is imperative that ProMedica comply with all federal and state statutes, a compliance
program too broad in nature will be ineffective. An effective compliance plan will be one that will
address the issues most critical to ProMedica, with the flexibility to add additional areas of concern.
Areas currently considered most critical include (click on the links to take you to the definition section):
Standards of Conduct – ethical standards for acceptable behavior
False Claims – billing & coding regulations supported by patient care documentation Compliance Plan
