Policies are part of the Seven Elements model. There are also various regulatory requirements that organizations develop policies on specific topics. Producing “the policies” is often a condition of initial licensing or one step in a compliance investigation by a regulator. And policy development (even submission and prior approval) has also been made a condition of settlement in numerous cases. So you’d think that guidance about the government's view of what constitutes a “compliant” (or at least good) policy should be easy to find. You’d think…
Requirements
The IRS is now requiring detailed information about governance practices of 501(c)(3) tax exempt organizations on their annual form 990 filings. Luckily they also provide information about what they are looking for.
To become Medicare Part A Providers (or change the ownership of an existing provider) organizations are being required to certify that they are in compliance with various civil rights laws AND produce copies of the policies that they rely on for that compliance. Luckily, the federal Office for Civil Rights has published sample policies.
AB 774 - California has not only set the requirements for hospital pricing policies – it also requires hospitals to submit their policies to a online, searchable database.
Beginning in 2014 Washington State is not only requiring hospitals there to have certain policies about Patient Rights but also to post them on their Internet site "where i[they are] readily accessible to the public, without requiring a login or other restriction."
Resources on Policy Writing
There is a classic 1956 Article on the role of policies and procedures in operating a particular program and morale within it, as well as a suggested method for creating ones that will “clarify and not confuse”.
The FBI has published Guidance for writing policies in a Small Campus Police environment.
And the Department of Justice has an extensive guide for developing policies in detention centers.
Requirements
The IRS is now requiring detailed information about governance practices of 501(c)(3) tax exempt organizations on their annual form 990 filings. Luckily they also provide information about what they are looking for.
To become Medicare Part A Providers (or change the ownership of an existing provider) organizations are being required to certify that they are in compliance with various civil rights laws AND produce copies of the policies that they rely on for that compliance. Luckily, the federal Office for Civil Rights has published sample policies.
AB 774 - California has not only set the requirements for hospital pricing policies – it also requires hospitals to submit their policies to a online, searchable database.
OSHA’s investigation guidelines describe specific content that should be part of hospital safety policies.
Required policy language relating to assistive devices for the deaf in a recent Consent Decree.
Beginning in 2014 Washington State is not only requiring hospitals there to have certain policies about Patient Rights but also to post them on their Internet site "where i[they are] readily accessible to the public, without requiring a login or other restriction."
Resources on Policy Writing
There is a classic 1956 Article on the role of policies and procedures in operating a particular program and morale within it, as well as a suggested method for creating ones that will “clarify and not confuse”.
The FBI has published Guidance for writing policies in a Small Campus Police environment.
And the Department of Justice has an extensive guide for developing policies in detention centers.
The Office of Management and Budget has collected resources on "plain language" at HowTo.Gov
The University of Idaho has posted a laudably simple "Policy Writing Guide"
The University of Wollongong also has a made "Writing A Policy Document" available.
The Centers for Medicare and Medicaid Services has a downloadable "Toolkit" for "Making Written Material Clear and Effective"
Sample Policies
The George Washington University publishes an "Employee Compliance Guide" with extensive weblinks to its policies.
The University of Texas Medical Branch at Galveston has its Compliance policies available online.
NYU's Langone Medical Center also shares its Compliance Policies
Tulare Regional Medical Center's compliance policies are based on RESPECT
Onslow Memorial Hospital Compliance has an entire website for its policies and related material.
Fraud, Waste and Abuse Awareness and Reporting Policy (Alaska Native Tribal Health Consortium)
False Claims Act and Whistleblower Education Policy (U of Maryland Medical System)
On research integrity (DHHS)
For rural co-ops (USDA)
"Best Practice” policies for non-profits in Maryland (MD OAG)
Model Corporate Compliance Program (USDOT)
The Hospital Corporation of America makes its Compliance and Ethics policies available to all
Boulder Community Hospital also has compliance policies
A policy about Compliance Training at Meridian Health.
Non-retaliation at Southern Illinois Healthcare
Policies at Stanford University's Do Research site
The policy behind the University of Texas' Systemwide Compliance Institutional Compliance Program
The University of Washington's School of Dentistry has Compliance Policies
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