Compliance is like a card game. Know the rules. Know the players. Know the stakes. Know who is looking over your shoulder - including the bartender! Choose your players / team- wisely.
Don't have a pile of chips on the table with no one guarding it- just waiting to see if any players show up. Eventually someone will show up and the chips will be taken by the member that held all the cards!
Compliance is in place to protect and ensure that the money a company has earned legally can be kept. Make sure your corporation has a compliance professional that has all the skills needed to win. Winning is not about being a cut-throat...but rather knowing the facts, using soft skills to get the point across, and identifying those who are bluffing (i.e. employment of the 7 Elements of Compliance, or 8 if you are playing in NY!)
CMS, OIG, DOJ....have given all of us the opportunity to have a full deck of cards and to know the stakes. Poker Face? The OIG even gives us the OIG Work Plan every year. Lots of free resources on the OIG and CMS websites. OIGhttps://oig.hhs.gov/compliance/101/CMShttps://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/downloads/Fraud_and_Abuse.pdfand https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNEdWebGuide/Downloads/MLN-Compliance-Webinar.pdf - to name just a few.
Do you have all the right players at your table to be successful in compliance? It is never too late to build a winning team!
Jacqueline Nash Bloink, MBA, RHIA, CFE, CHC, CPC-I/CPC, CMRS

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