Core 4.0 Pre-release

C-RM 1-2: Policy Addressing Reporting of Violations

Submited by: Tom Goddard

The Basics

This standard requires your organization’s compliance policies to:

  • Protect individuals reporting violations of ethical, regulatory, or legal requirements;
  • Address the consequences of failing to report violations; and
  • Protect the confidentiality of anyone reporting violations.

Management Tips

It will be important that your entire staff know about the mechanisms described in this standard. Be sure to include it in your compliance training.

Accreditation Tips

Desktop Review

The same set of P&Ps and/or program description you use for C-RM 1-1 should work here. Just make sure those policies have solid whistleblower protections and mechanisms to require reporting of violations.
Validation Review
This standard will be covered in the interviews of compliance-relevant management (including but not necessarily limited to the Compliance Officer), as well as interviews with staff throughout the company.

  • Core 4.0 Pre-release / 10.02.2018

    C-OPIN 3-3: Formal Acknowledgment of Compliance with the Organization’s Legal Requirements and Code of Conduct

    This standard requires a formal, signed acknowledgement from each staff member and all other "relevant persons" (members of oversight bodies and committees) that they:have access to the Code of Conduct;received compliance training, including training on the Code of Conduct;they understand the consequences of failure to comply with the Code of Conduct, the organization's policies, and applicable la...

  • Core 4.0 Pre-release / 10.02.2018

    C-OPIN 3-2: Staff Training Programs

    The organization must train its staff members in the following areas:Privacy and security of information (HIPAA, HITECH, and applicable state laws and regulations);New-hire orientation and training in role performance expectations before being allowed to assume the position;Healthcare ethics;The organization's code of conduct, which defines ethical business practices dealing, at a minimum, with co...

  • Core 4.0 Pre-release / 10.02.2018

    C-OPIN 3-1: Job Descriptions and Staff Qualifications

    This standard requires that your organization hires qualified staff, and that the measure of staff's qualifications is, in part on the extent to which staff meet the qualifications required by written job descriptions. In other words, each position in the organization has a written job description, and each staff member meets the qualifications of the applicable job description.Each such job descr...