You might think that a compliance program is too complicated and too time consuming to establish and implement, but imagine the Broncos or Seahawks trying to win games without developing a play book.   

I’m sure it takes a lot of time and resources to develop a play book, but how can you make it to the Super Bowl if someone didn’t invest in the time to do it?  

An effective Compliance Program is no different than a coach’s play book; it’s a process that requires continuous review and improvement and is based on two simple concepts:  a commitment to do the right thing, and the action steps necessary to make it happen.  

Here are some simple strategies that you can use right away to help you establish and implement a SUPER Compliance Program within your organization.

• Make a list of the program rules. Rules can be confusing and the complexity and evolution of the School-based Medicaid program certainly contributes to the confusion.  In order to comply with the rules, you first need to know them.

• Develop and adopt written policies and procedures to help you comply with the rules.  Your employees will know what is expected of them and you will have a framework to evaluate whether what should happen does happen, and what shouldn’t happen doesn’t happen.

• Develop a Compliance Plan around the 7 fundamental elements of compliance. Your Compliance Plan should provide details of how your organization conforms to specific rules to achieve and maintain compliance.  Be sure to review your Compliance Plan often and update it as needed.

• Be aware of your organization’s risk. Develop processes to identify problems upfront so you can do something about them before they become systemic and costly. 

• Get buy-in. Compliance is achieved by the efforts of the entire organization. Ensure everyone, especially key personnel, embraces your compliance program. Talk about your compliance efforts at staff meetings. Make sure everyone is aware of their contribution to the program.

• Provide Compliance Training. Make sure everyone understands the organization’s compliance policies and their responsibilities. Training should be applicable to the employee’s position and address risk areas. 

• Conduct internal reviews. You have to use some type of review to evaluate how well you are doing. This will help youl find the issues (you know they are there but you will never find them if you don’t look) and then you can do something about them!