It takes commitment to build a quality house – a commitment of time, energy and money to:
- Plan and design the house;
- Build and furnish it;
- Inspect, maintain and repair it;
- Add on or renovate it when needed; and
- To ensure that repairs or renovation work as planned.
Those commitments have to come from everyone involved in designing, building and maintaining the house. It has to include:
- The bank in committing enough money to build a quality house that will last and grow with your family;
- The owners in planning carefully, seeing the project through, and maintaining it in working order;
- The work crew in building it according to the plans and specs with attention to quality in all aspects, from the foundation to the crown molding; and
- From the family members who will use it as intended and be good stewards of the resources invested in building and maintaining the house.
The same is true of your compliance program. An effective compliance program takes the commitment of:
- The Company Owners, Managers and Board of Directors. Whether your company and facility[ies] are owned by a single individual, a partnership, or corporate shareholders, and whether your managing body (usually a Board of Directors or partners) is small or large, those folks have to dedicate sufficient resources to the program on a daily basis, including funds to set it up and run it, to provide quality of care, in billing and in all other aspects of facility operations, and to make sure the program and your operations are reviewed regularly and modified where necessary.
- The Architect, General Contractor and Work Crew. Think of your compliance officer (discussed below) and compliance committee (discussed below) as the architect, general contractor and work crew that will build and maintain your compliance program.
- The Family Who Will Live In the House. Think of your family and friends who will use the house as your employees and contractors who will inhabit the NF, make it run, help spot operations and compliance issues, and participate in preventing, spotting and correcting those problems when they occur.
Throughout this web-based guidance, we talk about effective compliance programs. The benefits a NF can gain from having a compliance program depend on the program being effective. The various federal documents produced by the OIG and the Federal Sentencing Commission, discussed later, all make clear that providers are rewarded only for effective compliance programs.