As part of the annual compliance program plan of work, nearly every provider includes a review of the policies that make up the program. You may not want to admit it for your organization, but typically that annual review of policies takes about 5 minutes when the compliance officer asks the members of the compliance committee if there are any changes to be made to the policies that impact their areas and everyone just shakes their head no. Check the box, annual review done, and on to the next task.
While it may be true there are no substantive changes to be made to the policy, it is important each year to actually read through the policy and ask the following questions:
- Do I understand this policy?
- Does this policy reflect what we do here?
- Is this policy written in a way it can be understood by everyone who must follow it?
Just having the policy is not enough. The policy must accurately reflect how things happen in the organization, and absolutely must be accessible to those who are expected to follow the policy. Being accessible means people must know where to find the policy and be able to read and understand it when they find it. Policies that are full of legalese and statutory language are hard to understand and even harder to follow.
The next time you are tempted to “check the box” when it comes to compliance program policy review, resist that temptation and have the discipline to take a few moments, read each policy and ask the three questions above. If the answer to any of them is “no” then it is time to consider re-writing the policy.