Question
In regards to compliance regulations (particularly requirements for having a compliance officer, etc.), how would regulations apply to a very small private practice that has only 2-3 employees?
Answer
You need to have a system in place with someone in charge, regardless of how small the practice; someone who can be put in charge of making sure everything is being followed as necessary. So if you have only three people in the practice, delegate one person as the compliance officer. The others could be part of the compliance committee because it is not always just about whether or not a co-worker is doing something wrong. You need to have a process in place, whether it is just one person or a larger organization with a committee. If you found out that somebody was fraudulent, wasteful or abusive, it needs to be reported to the right person. So there has to be at least one person that anybody can go to, either anonymously or through a hot line, that other employees, patients, or patient family members can go to with their concerns.
This Ask the Expert was taken from the course entitled: Compliance: More Than Just Following The Rules by Rex Crosby.
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Rex A. Crosby, OTR, has many years of experience as an Occupational Therapist in a variety of settings including Inpatient Rehab, Acute Care and Outpatient Neuro and Pediatric Rehabilitation. Rex also has extensive SNF experience as a clinical OT and Therapy Program Manager.
