Compliance codes out of compliance?


Hospital compliance codes are commonplace.   Ones that work with medical staff documents are positively exotic.
For the most part, compliance codes are painted with a very broad brush—or are downloaded from a very generic website-- and filed away in a drawer, to be pulled out when the feds are at the gate.  The author/consultant and often the compliance officer has no idea how many provisions conflict with medical staff bylaws, rules and regulations—adopted by the very same board of directors that signed off on the compliance plan.   
The hospital compliance code is supposed to address legal requirements for hospital and how to comply with them.  But medical staff bylaws, rules and regulations do too—at least the legal requirements pertaining to medical staffs, which are numerous.  (EMTALA, sexual harassment, financial conflicts of interest, to toss off a few).  Creating a compliance code without consulting the medical staff bylaws, rules and regulations in place that bind a major part of the hospital workforce should be unthinkable.    So-think about your hospital’s—and compare the documents.  Get rid of the inconsistencies. Note particularly the effect of violations and adjust the hospital compliance code to clearly state that medical staff member discipline is carried out under the medical staff process.