2.Ensure no one gets in the way. Healthcare CEOs should ensure that compliance officers are free of interference and able to do his/her job, Snell adds. "In my opinion, it is the single biggest impediment to the CEO’s success with a compliance program," the HCCA chief says.
3.Make time for your chief compliance officer. Your compliance officer should meet with you on a regular basis. During these meetings, the compliance officer should share reports showing all the functioning elements of the compliance program and provide a list of the issues that have been discovered by or reported to the compliance program, Snell adds.
4. Request audit reports. "An audit report listing the work being done to ensure you have addressed the issues identified on the OIG Work Plan would be helpful," Snell says. "The CEO should be informed of anyone interfering with the implementation of the compliance program or interfering with the resolution of issues."
5. Encourage balance between OIG and peers. Ensure that compliance officers focus on the issues the OIG intends to investigate, but also on issues that the compliance officer identifies from conversation with his/her peers in the field. "There should be a balanced effort on all the elements of a compliance program," Snell says, "but I would focus more on auditing and resolving problems."
6.Keep the board informed. The CEO should not deliver the compliance reports to the board. Rather, the compliance officer should meet with the CEO prior to the board meeting, and together they should report to the board. "The reports should be essentially an executive summary of the reports mentioned previously," Snell says.