Review Compliance Program Guidelines
Posted: Thursday, May 20, 2010
by Rose-Marie Chaperon
Chaperon Consulting, LLC
What is compliance? It s the act of complying, acquiescence and a disposition to yield to or comply with others. How would one write an effective compliance program? As with any policies and procedures one creates it must have a purpose to begin with. Then after the purpose has been established the following components must be established. An effective compliance program must have a corporate structure, an officer must be established, a report must be set in place, there must be a way to investigate issues, they must establish training methodology, audits and cooperation and responsibility.
It is imperative that a compliance officer is in place in order to make the program effective. The position of compliance officer should be to establish and to ensure that all employees are aware of and understand the code of the company code of conduct and to administer and deliver an effective program. The compliance officer position usually reports to the president of the pharmacy and from time to time, to the board of directors if there is such position. A compliance officer should have responsibilities such as designating appropriate supervisory employees and officers to assist in administering and to ensure that all employees receive and acknowledge in writing receipt of the program. He or she also has the responsibility of training.
Reporting and preventing unethical and possible compliance issues is also a key factor in a proper compliance program. A compliance officer should have the responsibility to report monthly statistics to the president or CEO concerning all activities regarding the pharmacy's code of conduct.
As with many programs, investigation of issues should be done and reported whenever a violation becomes apparent. An investigation must be document with a plan of action. Sometimes it may be relevant for the compliance officer to recommend that the pharmacy hires independent consultants to conduct such investigation on its behalf.
An audit is a way to verify or examine an account(s), to ensure that the compliance program is working properly, the officer should perform random audits periodically. Depending on the size of the company, the officer may suggest that the company hires an outside firm or consultants to ensure and validate the program. Training plays a major role in any company's or program success. When a corporation invests time in training its employees, it calls for better retention and ensures that everyone across the board is performing equally (Brewer, 2009) . The compliance officer should provide the training to all employees including the leadership team. As an officer I would retain a written knowledge of the program and training validation from everyone who have attended. Depending on how many positions there are in the pharmacy, there should be some further specialized training for key positions such as billing and collections. Cooperation, responsibility, and integrity are very essential parts of a compliance program. the responsibility should be everyone's responsibility. The compliance officer should in part ensure that everyone is following and cooperating with the company's code of ethics. A compliance officer job never stops, the officer should always stay on top of regulatory compliances news and updates. The officer, although should report to the company's CEO or president should also be able to make difficult decisions with matters that involve the administrative team.
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