Mitigate Organizational Risk by Maintaining an Effective Compliance Program

As the rapidly evolving COVID-19 situation impacts healthcare organizations worldwide, now more than ever, the importance of staying informed is vital to ensure the wellbeing of your workforce and to mitigate organizational risk. With the changing regulatory environment, it is critical that each Compliance Program has a plan in place to identify, process, and address each regulatory update for all affected programs and departments. We recommend that the Compliance Committee meeting agendas include these areas. During this time of crisis, it may be beneficial to increase the frequency of the Compliance Committee meetings, to be able to adequately address the rapidly changing environment. Keep in mind that Compliance Program regulations/requirements/guidance has not been modified at this time.

Additionally, the following tips are recommended:

1. Ensure that your organization maintains open lines of communication across departments and teams via virtual meetings and conferences. Include messaging addressing the impact on staff morale and emotional wellbeing as well as the impact on business practices.
2. Keep abreast of your industry’s regulatory changes and share updated guidance documents with your stakeholders.
3. Ensure that your Corporate Compliance and Quality team members have a voice at the table when developing strategies and action plans.
4. Review and update existing policies and procedures. Determine where updated policies and procedures and links to interim guidance documents will be maintained for easy access by your stakeholders.

Links to various websites and key guidance documents can be found below; we recommend that you check them for updates regularly:

NYSDOH

• NYSDOH Homepage
• NYSDOH Medicaid Information
• NYSDOH Healthcare Provider Information

OIG

• OIG Updates

OPWDD

• OPWDD COVID-19 Guidance
• OPWDD Services Billing Guidance

Managed Care Community of Practice

• Managed Care Community of Practice Homepage

OMH

• OMH Guidance

OASAS

• OASAS Keywords
• OASAS COVID-19 Information

SED

• SED Announcements

OSHA

• Guidance on Preparing Workplace for COVID-19

CDC

• Prevention Methods

In addition, HHS has issued several guidance documents, with examples and cautions, addressing disclosures by covered entities in the following areas:

• Disclosures to law enforcement and first responders.
• Disclosures to public health authorities.
• Use of telehealth (acceptable non-public facing devices).

More information is available here.

If you have questions or need further guidance, please do not hesitate to reach out to the Compliance team. Click the button below for more Bonadio Compliance Solutions information.

The information and advice we are providing for this matter relates to COVID-19 legislative relief measures. Because legislative efforts are still ongoing, we expect that there may be additional guidance and clarification from regulators that could modify some of the advice and information provided to you, after the conclusion of our engagement. We therefore make no warranties, expressed or implied, on the services provided hereunder.