ABSTRACT

Introduction Seven key elements must be considered with any healthcare compliance program. A CBR compliance program is specialized and must also appropriately interface with a corporate compliance program and with other specialized programs such as laboratory, pharmacy, home health, or skilled nursing. Thus, the forms and structures of a CBR compliance program and an associated written plan will vary considerably for each hospital, clinic, or integrated delivery system. For larger organizations [integrated delivery systems (IDSs) or hospital systems with multiple clinics], a CBR compliance program will most likely be relatively freestanding with all seven key elements in place. In a smaller setting, e.g., a single hospital, it is likely that a compliance program will be more closely integrated into a corporate program to the point that only certain elements are in evidence, primarily specialized policies and procedures.