Improving Compliance by Adopting and Updating a Compliance “Treatment” Work Plan

Federal and state enforcement agencies expect providers to have a compliance plan. Too often providers postpone developing a compliance plan or allow the plan to become stale due to cost concerns and/or not knowing where to start. However, compliance plans and processes do not need to be expensive or super-comprehensive to be effective and helpful. The most effective plans start small and adapt over time. One approach that can help providers get started is to imagine your organization as a patient in need of ongoing care—not a one-time procedure but a series of targeted treatments, checkups, and therapies. Your compliance plan, and particularly your Compliance Work Plan, function as your compliance “treatment plan,” translating your compliance goals into measurable, time-based objectives and interventions. By updating it throughout the year, you can facilitate clarity, accountability, and continuous improvement.

Executive Summary

• Develop a “Treatment” Work Plan: Treat your compliance program like a patient—assess your compliance
  risks, develop compliance goals, and address them through a tailored work plan.
• Define Measurable, Time-Based Goals: Establish short-term goals designed to help you achieve long-term
  objectives, each tied to clear metrics and deadlines.
• Deploy Targeted Interventions: Use education, internal and third-party audits, and follow-up training as the
  “therapies” that drive progress toward your goals.
• Monitor and Adjust Continuously: Hold monthly huddles and quarterly plan revisions, and report progress
  to leadership—ensuring your plan remains aligned with evolving risks and regulations.

Your Compliance Treatment-Work Plan

1. Diagnosis (Risk Assessment): At least annually, your compliance officer should coordinate with key personnel and experienced legal counsel and complete a comprehensive risk assessment to uncover high-risk areas– exclusion screening, physician contracting, upcoding, areas generating complaints, unexplained changes in billing patterns, common claim denials from audits, etc.
2. Treatment Goals (Compliance Objectives):
   • Long-Term (6-12 months): Address the risk areas by setting long-term goals (e.g., improving medical director time-sheet documentation; increasing staff awareness and evaluation of Code of Conduct; reducing telehealth claim denials by 25%, etc.)
   • Short-Term (0-6 months): Develop short-term goals designed specifically to help achieve the long-term goals (e.g., auditing each medical director time sheet by assembling materials documenting performance and interviewing collaborating personnel; achieving 95% completion of annual training and quarterly mini-training sessions on Code-Of-Conduct; completing root-cause analysis of telehealth claim denials and developing education and process or documentation improvements and completing internal claims audits within 3 months, etc.)
3. Interventions (Compliance Activities): Just as clinicians prescribe therapies, your work plan’s interventions should focus on activities reasonably expected to improve compliance:
   • Education & Training: Identify and task personnel to conduct targeted education programs; live workshops on updated billing rules; and on-demand modules for emerging fraud-and-abuse risks.
   • Internal Audits: Identify and task personnel with completing monthly chart reviews focusing on identified risk areas; task a working group with completing quarterly “deep dives” to perform a multi-disciplinary evaluation of education impact and possible process improvements.
   • Third-Party Validation: Contract with a third-party expert to audit a percentage of internal audits to evaluate and improve quality of internal audits.
   • Follow-Up Education: Schedule additional education or information discussions informed by audit findings, with post-training quizzes to gauge effectiveness.
4. Continuous Monitoring and Plan Updates
   • Regular Meetings: Add Compliance as a standing topic for regular meetings (3-5 minutes);
   • Monthly Huddles: Compliance officers and department liaisons review audit results. training rates, and new risks.
   • Quarterly Revisions: Update goals and interventions to reflect fresh regulatory alerts, audit insights, or shifts in operations.
   • Board Reporting: Deliver a concise “treatment progress” summary at each board meeting highlighting achieved milestones, course corrections, and upcoming objectives.
5. Benefits of a Compliance “Treatment” Work Plan
   • Enhanced Visibility: Provider staff sees exactly how high-level policies translate into day-to-day actions and outcomes.
   • Greater Efficiency: Coordinating resources and efforts increases effectiveness and avoids regression.
   • Stronger Defensibility: A well-documented, data-driven plan provides powerful evidence of good-faith efforts– key to rebutting FCA knowledge allegations; helps potential undetected billing errors remain overpayments rather than False Claims Act violations with treble damages and civil fines.
   • Empowered Staff: The treatment plan approach helps improve staff comprehension and buy-in by presenting compliance within a cognitive framework the staff is already used to.

Conclusion
Just as a personalized medical treatment plan guides patients to better health, an individualized, adaptive compliance work plan drives your organization toward more effective and defensible compliance. Define clear goals, deploy targeted interventions, and monitor progress year-round to turn compliance from a static document into a dynamic, results-driven practice that your staff understands and values. A stronger, living compliance plan not only helps you prevent violations but also helps shield your organization from the disruption and cost of government investigations. providers should consult with experienced healthcare legal counsel to discuss and assess their compliance and targeted ways to implement effective improvements.

“Improving Compliance by Adopting and Updating a Compliance “Treatment” Work Plan”

Louisiana Hospital Association Impact Law Brief, Vol. 40, No. 4. Apr. 2025

Written by Michael Schulze and Heather Arrington