Creating a Culture of Compliance

By: Julie Sheppard, BSN, JD, CHC

The rules and regulations that govern compliance in a medical practice are serious and cannot be overlooked. In addition to HIPAA and OSHA, there are federal fraud and abuse laws that require the careful attention of physicians and staff.

Keeping your practice compliant with these rules and regulations takes time, resources, and constant vigilance. However, taking the time to create a culture in which compliance is integrated keeps your practice free from the vulnerabilities and risks associated with non-compliance.

As most already know, compliance is comprised of a mesh of complex rules and regulations that involve many details. Multiple healthcare enforcement agencies create a need for your medical practice to stay focused on following the applicable laws. The success of your compliance program stems more from the culture of compliance within your practice than on completing checklists, and begins at the top with the physicians and administration.

Creating a culture of compliance is distinct from merely adhering to rules and regulations. In fact, the Health Care Fraud Prevention and Enforcement Action Team (HEAT) Provider Training materials address the importance of a culture of compliance:

Compliance Comes From Above

Physician and practice administrators must recognize the importance of setting the tone at the top. Developing a proactive compliance program conveys the importance of compliance publicly and helps the staff understand that you are committed to making the right decisions regardless of the rules and penalties. A properly implemented compliance program reaches far beyond the policies and procedures in the manual.

Here are a few tips to keep your compliance program going strong:

  1. Administrators and partners/physicians should convey the level of importance of the program by participating in training, etc.
  2. Communication must be kept open, so that staff members feel comfortable speaking up.
  3. Make sure everyone understands that the underlying reason for the program is to consistently do the right thing.
  4. Everyone in the practice needs to view compliance as his or her responsibility.
  5. Make it a way of life at the practice by integrating it into the daily operation.

Education is essential to establish a culture of compliance. Employees need to understand the compliance risks that exist for your practice, and the importance of adopting a compliance program to mitigate risk and protect the practice. Additionally, while the office staff is typically those responsible for upholding the regulatory standards on a daily basis, it is the responsibility of the physician(s) and administrators to lead by example, and to set expectations for compliance with the staff.

Creating a culture of compliance and developing a proactive compliance program can ultimately help your practice reduce risks, improve your efficiencies, reduce your administrative costs, and gain better overall control of your practice.Now more than ever it's necessary to ensure compliance to protect the wellbeing of your practice. There are resources* to help guide you to make compliance less daunting. With the right mindset, leadership, and support, compliance can be a more manageable and integral part of your culture.

* The Office of Inspector General has provided resources with specific guidance for medical offices:
-A Roadmap for New Physicians: Avoiding Medicare and Medicaid Fraud and Abuse
-OIG Compliance Program for Individual and Small Group Physician Practices

Julie Sheppard, BSN, JD, CHC is President and Founder of First Healthcare Compliance. First Healthcare Compliance ( addresses the challenges created by the recent compliance mandates of the Affordable Care Act (ACA) for healthcare providers, specifically for private physician practices, by developing a timely, comprehensive, and practical solution to meet their ongoing compliance needs.