In order to ensure compliance to the Sarbanes-Oxley Act (SOX) in a hospital setting, the following plan could be adopted:
Come up with a committee to deliberate on the compliance process, this committee should be sources from all departments of the hospital. It may be constituted of: The Chief Executive office, the Chief Medical Officer, the Chief Operating Officer, the Chief Information Officer, and the Chief Financial Officer. The office of Compliance Officer should be created if no such office exists, if it does, the Compliance Officer should be a member of the committee.
Under the Compliance Officer, a core committee called the SOX implementation committee should be set up. This team should be tasked with the development of and elaborate plan that will be executed in search for SOX compliance.
With the core SOX implementation team in place, each fundamentally financial undertakings of the hospital should have one person select to work hand-in-hand with the implementation team. The essence of this is to ensure that relevant and pragmatic controls are in place.
The different undertakings are then critically analyzed and placed on a timeline within which they will be implemented; this should be done in phases. This step aims at dividing the different undertakings into phases that are measurable and can be monitored.
Through continuous assessments and evaluations the progress of the implementation should be monitored and recommendations derived and upheld. The employees should also be enlightened about their responsibilities and consequences of their action or inaction with regards to matters surrounding the SOX implementation.
Employees in the auditing and accounting departments can be more knowledgeable on SOX’s major provisions, if an elaborate participatory process is instituted by the hospital’s administration. This could be in the form of hiring legal companies to undertake training, organizing conferences and seminars to educate them on SOX provisions and making SOX compliance knowledge a requirement upon the hiring of new staff.
In order for top executives of the company to comply with the Act, it is pertinent that they have crystal clear knowledge of the provisions therein. If this is as the case, it is noteworthy that they understand the guidelines and the implications of the act. The top executives should set interior controls that will check the process of junior employees and through continual reporting and auditing can ensure compliance. Finally, through continual consultancy on the compliance process, the top executive can achieve it.
Conflicts of interest identification has no universal approach. It could be either a perception or be an actual existence. However, it can be identified by evaluating the officers interests, public versus private; assessment of any potentialities of such existence or existence of perceptions of conflict of interest; and proportionality of involvement. Furthermore, the officer’s presence of mind has a lot to speak about it. Lastly, the promises that the officer commits to uphold to the company vis-à-vis the status quo speaks volumes about such commitment.
Marchetti, A. M. (2007). Sarbanes-Oxley ongoing compliance guide: Key processes and summary checklists. Hoboken, NJ: John Wiley & Sons.