How to Get Proactive for Your Healthcare Client’s FDR Compliance Requirements
I’ve been with ETHIX360 as the Chief Compliance Officer for a little over a year and half. During this time, we’ve built an ethics and compliance program that fosters a culture of partnership and integrity. Through the strength of the partnerships, we seek ways to become a better, stronger provider of hotline/ whistleblower, case management platforms. As a First-Tier, Downstream and Related entity (FDR), we take our additional partner responsibilities very seriously.
Organizations in the healthcare sector are responsible for ensuring its FDRs meet the compliance requirements of the Medicare program, and this isn’t an easy undertaking. ETHIX360’s healthcare clients are responsible for their own internal compliance program as well as the programs of their FDR’s. So not only are they managing their own compliance-crazy, they have to keep an eye on their downstream vendors compliance-crazy. And most of them are working with multiple FDR’s. To that end, anything I can do to make their lives and jobs easier, I’m 100% onboard to do.
One of the first projects I undertook when I join ETHIX360 was to create what I refer to as a “Healthcare Client Welcome Packet.” I want our healthcare clients to think of me as a resource, a “welcome wagon” team, but instead of gifts and coupons, I give proof wrapped in a nice red virtual bow. I’m a firm believer in taking a proactive approach to compliance. Being proactive makes my life easier because I know we are going to pass our audits. It also makes our healthcare partners life easier, because they know that they can count on us.
What does an FDR Compliance Welcome Packet consist of? So glad you asked!
Our Employee Universe – A list of all ETHIX360 employees
All things training – From copies of the training to the proof they’ve been completed by every employee
Copies of all relevant policies and procedures and attestation proof
Dates for completed Conflict of Interest forms
Evidence of screening for Excluded Individual
The most important piece in my healthcare welcome packet is setting up a relationship based on responsive and open communication. I recognize that our healthcare clients have unique and specialized regulatory needs. They are often under a lot of pressure, many times, with deadlines beyond their control. To that end, all of ETHIX360’s clients have my cell phone number and are encouraged to reach out to me at any time. I always tell clients that if they’ve been given an insane deadline to provide evidence their FDRs are compliant, reach out to me… if it’s urgent, just say the word and I’m on it.
I think all compliance professionals are fighting for the same cause, but perhaps from slightly different angles. Ultimately, we want to meet all legal FDR compliance requirement, but that’s just the baseline. As a rule, ethics and compliance professionals want to empower their employees, improve corporate culture and positively impact our communities. I take pride in my job knowing I’m successful when I can help my fellow compliance professionals be successful. The FDR Welcome Packet and the partnership that is created is not just good business, it’s the right thing to do.
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MEET THE AUTHOR
Stephanie Farmer is a seasoned ethics and compliance (E&C) professional. She has earned an MA in both Business and Professional and Applied Ethics and is a graduate of The Ethics & Compliance Initiative Managing Ethics in an Organization Program. Prior to and during her E&C career, Stephanie served in the United States Marine Corps Reserves and the North Carolina Air National Guard.
ABOUT ETHIX360
At ETHIX360, our goal is simple: to provide an affordable, flexible, and comprehensive answer to employee communication, policy management, corporate training and case management on issues related to corporate ethics, code of conduct, fraud, bribery, and workplace violence.
