Ann & Dan's compliance corner
Welcome back to Ann & Dan's Compliance Corner! Here, you'll find updates on compliance issues you want to know about. This month, we introduce our new Code of Conduct and give you tips on implementing your own Code of Conduct. (Missed last month's column on Medicare rules on waivers of co-pays and deductibles? Click here.)
Our clients already know that athenahealth has high standards for how we conduct ourselves and perform our work. Now, our newly-updated Code of Conduct is integrated with our mission statement. In order to become the most trusted and effective business service provider to physicians, each employee agrees to deliver:
- INTEGRITY - Follow the highest legal and ethical standards and require the same of those with whom we work
- QUALITY - Provide athena services in a compliant, timely, and accurate manner
- PRIVACY - Protect customer, patient and athena confidential information
- INITIATIVE - Know the Code of Conduct, and prevent, or report and resolve possible violations
Why a written code of conduct? First of all, a formal Code helps us fulfill our mission of being the most trusted and effective business service to medical offices. We work with sensitive and confidential information relating to our clients and your patients, and we want you to know we take our responsibility for protecting that information very seriously.
Of course, having a well-publicized Code of Conduct is required by various federal rules and encouraged by the U.S. Department of Health and Human Services (HHS). But we believe that official requirements are only the first step when it comes to developing a living, breathing Code of Conduct. The foundation of a well-structured Code also includes the company's reality in the business world, and what employees can accomplish. So we've chosen to focus on language that can be used every day in real life by our employees - and we recommend the same for our clients.
Every one of our athenistas is expected to know the Code and to live it every day that they work at athenahealth. In fact, an abbreviated version of the Code is printed on every employee's ID badge. Our managers apply the Code to policy development, and ongoing training and education. And if an employee faces a specific challenge in his or her work, a quick reference to the Code of Conduct can provide guidance for handling the issue.
Keep in mind that HHS encourages all healthcare practices to have written standards of conduct as part of an effective compliance program. Here are some tips for developing or updating your own practice's code of conduct:
- Make it memorable. Does your compliance point person actually remember the Code without reading it? Do your employees?
- Make it practical. Put yourself in realistic, compliance-related scenarios and imagine how your Code of Conduct can offer guidance and direction.
- Make sure it measures up. Consult the HHS Office of the Inspector General's Compliance Program Guidance for Physician Practices. Your code of conduct should contain at least the elements outlined here.
- Keep it alive. Keep your Code a part of your everyday work by getting buy-in from all staff, and incorporating it into training and policy development.
To read athenahealth's full Code of Conduct, click here.
Disclaimer: The content of Compliance Corner is for general informational purposes only, and should not be interpreted as compliance guidance or advice. Consult your compliance advisor or attorney for compliance or legal advice on specific issues related to your practice or compliance program.