- HET Resources
Benchmark Resources - benchmark models and measures of program effectiveness, code of conduct provisions, compliance policies and procedures, hotline operation and most elements of ethics and compliance programs.
The Compliance Officers Checklist (Adobe PDF) MEMBERS ONLY
The Ethics Test® (Adobe PDF) MEMBERS ONLY
The Hotline Effectiveness Checklist (Adobe PDF) MEMBERS ONLY
The Hotline Handbook - guidelines for establishing and operating the hotline. (Other Council publications)
The Pastin Report on Healthcare Compliance Programs - a monthly newsletter on practical issues faced by ethics, compliance and integrity officers in healthcare organizations. (Back issues / Excerpts)
Talk About Compliance - An e-mail list-serve.
The material in this area is proprietary and protected by copyright registration to the Council of Ethical Organizations. Reproduction or dissemination-by any means-including photocopyingand transmittal by FAX-is a violation of federal copyright law (17 USC 101 et seq) punishable by fines of up to $100,000 per violation. Violators will be prosecuted. Do not copy, quote, duplicate electronically or by any means disseminate without specific written permission.
- Government Resources
- The federal government web sites are excellent sources of information concerning issues that are important to, or affect the operation of, corporate compliance programs. The following are just SOME (by no means all) of the web sites that contain documents and information with which all compliance professionals should be familiar.
A. Department of Health and Human Services Office of Inspector General
OIG Workplan 2007 (outline of major projects, including audits, investigations, enforcement actions etc. to be undertaken by the OIG during the fiscal year): http://oig.hhs.gov/publications/docs/workplan/2007/Work%20Plan%202007.pdf
OIG Red Book 2002 (describes proposed cost saving measures and actions to be taken to save money in government funded healthcare programs): http://oig.hhs.gov/publications/docs/redbook/2002%20Red%20Book.pdf
OIG Semi-Annual Reports (description of activities including enforcement procedures concluded during the relevant period most recent reports are April-Sept 2002 and Oct-March 2002): http://oig.hhs.gov/publications/semiannual.html#1
Compliance Guidances (proposed compliance plans for specific healthcare industry segments, e.g. hospitals, small physician practices, home health agencies, labs, etc.): http://www.oig.hhs.gov/fraud/complianceguidance.html
Fraud Alerts/Bulletins (OIG notices of issues or practices that are deemed suspect and which OIG is likely to investigate in the near future): http://www.oig.hhs.gov/fraud/fraudalerts.html
OIG Advisory Opinions (formal opinions from the OIG, concerning specific arrangements, programs or activities by providers, determining whether the identified practice or program would be subject to sanction under federal law): http://oig.hhs.gov/fraud/advisoryopinions/opinions.html (for 2003 and 2002 opinions)
B. DHHS Centers for Medicare and Medicaid Services (Medicare and Medicaid Program Manuals and Memoranda): http://www.hcfa.gov/pubforms/progman.htm
C. HIPAA Privacy Regulations (final regs published in the Federal Register 12/28/00): 65 Fed. Reg. 82462-29; text found at: http://aspe.os.dhhs.gov/admnsimp/final/PvcTxt01.htm
Final Final Privacy Regulations (incorporating changes proposed in March 2002 and additional modifications): http://www.hhs.gov/ocr/hipaa/
Final HIPAA Security Regulations (published in Federal Register on February 20, 2003): http://www.access.gpo.gov/su_docs/fedreg/a030220c.html
Final Transactions and Code Sets Regulations (published February 20, 2003):
http://www.access.gpo.gov/su_docs/fedreg/a030220c.html
Model Compliance Plan and Instructions for Electronic Filing of Plan (to obtain one year extension on October 2002 deadline for electronic health care transactions requirements): http://www.cms.hhs.gov/hipaa/hipaa2/default.asp
Office of Civil Rights (up to date postings on government actions with regard to HIPAA including first Guidance document): http://www.hhs.gov/ocr/hipaa/
FAQ (Frequently Asked Questions) Guidance Memo from OCR published in October, 2002: http://www.hhs.gov/ocr/hipaa/assist.html
D. STARK II "Final Regulations" Phase 1 (published in the Federal Register on January 4, 2001) at 66 Fed. Reg. 856; text found under Health Care Financing Administration at : http://www.access.gpo.gov/su_docs/fedreg/a010104c.html
E. US Sentencing Commission
Federal Sentencing Guidelines (including description of elements of an "effective corporate compliance program"): http://www.ussc.gov/guidelin.htm
F. US Department of Justice
"What’s Hot" page (current issues of concern or interest to the Justice Department, including areas of heightened enforcement or investigation): http://www.usdoj.gov/01whatsnew/01_3.html
G. Federal Trade Commission
Privacy Initiatives (e.g. Children’s Online Privacy Protection Rule; Gramm-Leach-Bliley Act): http://www.ftc.gov/privacy/index.html
H. Government Accounting Office (GAO)
Daybook listings (publications of reports, audits, Congressional testimony by subject areas): http://www.gao.gov/daybook/daybook.htm
I. Sarbanes-Oxley
Federal statute: http://news.findlaw.com/hdocs/docs/gwbush/sarbanesoxley072302.pdf
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