Dan Ostergaard · Co-founder, Trusty · Former Novartis Global Head of Compliance · Founder of PolicyStore
The healthcare landscape is continuously evolving, and staying compliant with regulations is a challenge, especially for Small and Medium Enterprises (SMEs).
The OIG’s GCPG of November 2023 offers valuable insights and directives for healthcare providers of all sizes. However, the nuances for smaller providers deserve special attention, as they often face unique challenges compared to their larger counterparts.
1. Understanding the GCPG for smaller providers
The OIG’s GCPG is a comprehensive resource designed to assist healthcare entities in navigating the complex world of compliance. For smaller providers, this guidance is a beacon, illuminating the path to compliance in a sector fraught with regulations.
Step 2: how do you tailor the compliance approach?
Recognizing the resource constraints of SMEs, the GCPG suggests a tailored approach to compliance:
- Compliance Contact: Instead of a full-time compliance officer, SMEs can designate a knowledgeable individual responsible for overseeing compliance.
- Customized Policies and Training: Develop policies and procedures that are relevant and practical for the size and complexity of the SME. Ensure all employees are trained and aware of these policies.
- Open Communication Channels: Establish clear, accessible channels for reporting compliance issues, emphasizing confidentiality and a no-retaliation policy.
3. Risk assessment and monitoring
Conduct regular risk assessments to identify potential areas of non-compliance, focusing on high-risk processes. Auditing and monitoring should be scaled to match the SME’s operational scope.
4. Enforcing compliance standards
Implement a system of consequences and incentives to enforce compliance standards. This includes disciplinary mechanisms for non-compliance and recognition for adherence to compliance protocols.
5. Responsive action to compliance issues
SMEs should be agile in responding to detected compliance issues. Prompt investigation and corrective actions are crucial in maintaining compliance integrity.
6. Creating a compliance-oriented culture
A culture that values ethical behaviour and compliance is essential. Leadership in SMEs should actively promote this culture, encouraging open communication and ethical practices.
You can access the OIG’s GCPG HERE.
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Frequently asked questions
A resource published by the US Office of Inspector General in November 2023 to help healthcare entities of all sizes build effective compliance programmes.
By designating a knowledgeable compliance contact instead of a full-time officer, developing policies and training that fit its size and complexity, and setting up accessible, confidential reporting channels with a no-retaliation policy.
Through regular risk assessments focused on high-risk processes, with auditing and monitoring scaled to the SME's operational scope.
Enforcing standards with consequences and incentives, responding promptly to detected issues with investigation and corrective action, and building a culture in which leadership actively promotes ethical behaviour.
Related reading: why scaling your business should not scale your liability, why US companies need whistleblower software, and the Compliance App for policies, training and reporting in one place.
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