Como implementar um programa de compliance em sua instituição de saúde

Dra. Claudia Montanha, presidente da Comissão de Saúde da OAB/PR e sócia do escritório Montanha, Alcântara & Advogados Associados

Implementar um programa de compliance em qualquer tipo de empresa não é como seguir uma receita de bolo. Uma empresa ou instituição de saúde, com todas as especificidades e protocolos próprios, pode ser ainda mais particular. O primeiro passo, segundo a advogada atuante em Direito Médico, Dra. Claudia Barroso de Pinho Tavares Montanha, presidente da Comissão de Saúde da OAB/PR, é estudar a fundo toda a estrutura da empresa. Dependendo do tamanho e da idade da instituição, o processo pode levar vários meses. “Não é apenas seguir um padrão. Para instituir e alinhavar um programa de compliance, é preciso estudar toda a estrutura interna da empresa e sua forma de atuação, para eliminar qualquer possibilidade de risco a que ela esteja sujeita, por exemplo, em uma fiscalização, nos contatos com seus fornecedores, distribuidores e a administração pública”, afirmou a Dra. Claudia Montanha, sócia do escritório Montanha, Alcântara & Advogados Associados, que presta assessoria jurídica à WMC Anestesia e à Sociedade Brasileira de Anestesiologia, entre outras instituições de saúde. “É preciso tomar toda cautela possível, porque não basta ter o manual de compliance apenas como um documento, ele precisa ser efetivo.”

Veja também: Você já se comprometeu com o compliance hoje? Comprometimento é o desafio para o compliance na saúde

O compliance – do inglês to comply: cumprir, estar em conformidade, estar de acordo com as regras ou as leis – é uma ferramenta de auxílio ao empresário para que ele cumpra todas as suas obrigações legais e éticas na condução da empresa, não apenas para trabalhar da melhor forma, mas para não correr risco de penalizações. Os programas de compliance visam a estabelecer mecanismos e procedimentos que transformem o cumprimento das legislações e das regras em uma cultura cooperativa.

Segundo a Dra. Claudia Montanha, quando se adere a um programa de compliance, não significa que os riscos vão diminuir em sua concretude, mas um programa bem estruturado, coerente e adequado pode minimizar esses riscos. “É um instrumento relevante, que permite que os agentes contribuam para o combate a fraudes e à corrupção”, disse ela na palestra “Combate de Fraudes e Implantação de Modelos de Compliance”, do painel “Gestão Disruptiva em Organizações de Saúde”, do 8º AnestEdu.

Ter esse manual de integridade também pode representar uma vantagem competitiva no mercado. A Dra. Claudia Montanha afirmou que, pela própria experiência em análise e conferência contratual, pode afirmar que o compliance está se tornando uma exigência: “Mais do que um diferencial, hoje, ter um programa de compliance é uma necessidade”.

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Pilares da implementação de um programa de compliance em uma instituição de saúde

Segundo a Dra. Claudia Montanha, embora não haja um manual de compliance aplicável a todas as empresas, há alguns pilares da conformidade que não podem faltar em qualquer programa de compliance e sua implementação e operacionalização. Veja abaixo os pilares do compliance, conforme explicados pela Dra. Claudia Montanha:

Compromisso assumido pela alta direção

Não há programa de compliance efetivo que não conte com um compromisso genuíno de toda a direção. É o que vai conferir credibilidade. Os colaboradores de uma empresa só vão aderir e mudar de comportamento a partir do exemplo da alta direção.

Por exemplo, quando a L’Oréal contrata um novo funcionário, em seu primeiro dia, esse funcionário recebe os documentos das mãos de um funcionário do alto escalão da empresa. Esse funcionário da alta direção entrega ao novo funcionário documentos como o contrato de trabalho e o manual de compliance da empresa, dizendo “se esse manual é importante para mim e para a empresa, também será para você. Leia, consulte e, qualquer dúvida, venha falar comigo”. Isso sela o compromisso sério da empresa com o novo colaborador.

Avaliação de riscos

É necessário detectar frequentemente a existência dos riscos a que a empresa possa estar sujeita, ou seja, analisar constantemente as formas de conduta da empresa, como essas condutas são colocadas em prática e como podem oferecer riscos. Quando se dá início a um processo de compliance, é como ter um filho, é um compromisso para o resto da vida da empresa. É preciso alimentar e revisar os procedimentos nesse documento único que vai ajudar a melhorar a performance da instituição e evitar qualquer condenação no futuro. A avaliação de riscos é contínua porque as condutas mudam, a evolução vem em todos os setores e o manual de compliance tem que acompanhar isso.

Como eu monitoro os riscos? Supervisionando todas as áreas da empresa, verificando se o programa de compliance está sendo realmente colocado em prática e se todos estão aderindo ao manual de compliance. Monitoro também por meio de auditorias, e o grande desafio não é somente detectar e sanar os riscos, mas garantir a perenidade desse processo.

Manual de condutas claras

Deve ser elaborado um documento prevendo regras, treinamentos, etc. Um manual distribuído a todos da equipe irá significar o desejo da empresa de estar em conformidade com a lei e de que o funcionário também esteja. As regras precisam ser claras, para que todos compreendam e possam consultar e aplicar.

Criação e propagação da cultura de compliance

Como a realidade das empresas é muito mais rica do que possa constar em um manual, porque tudo evolui, a cultura de compliance da empresa deve ir muito além do que estiver contido no manual. Entretanto, ele deve conter regras claras para garantir o bom funcionamento e a segurança a todas as negociações e a todos os relacionamentos dentro da instituição, promovendo um compromisso verdadeiro entre dirigentes, funcionários e o próprio manual, reduzindo riscos e definindo metas, treinamentos e padrões de conduta.

De que forma? Pode ser instituído, por exemplo, o Dia do Compliance, com atividades, dinâmicas e treinamentos permanentes para reafirmar o compromisso de estar em conformidade. Podem ser distribuídas cartilhas, até para ilustrar o manual. Podem ser utilizados exemplos de casos de empresas que adotaram a cultura de compliance e deram certo e, por outro lado, de casos investigados de empresas que não adotaram o compliance e foram condenadas.

Canais de comunicação

Imprescindíveis, canais de comunicação, como ouvidoria on-line, número de telefone e e-mails proporcionam aprimoramento ao programa de compliance. Esses canais devem servir para tirar as dúvidas de todos na empresa, tanto dirigentes quanto funcionários, e para receber denúncias de crimes e condutas que possam ser tipificadas como ilícitos. É necessária uma equipe muito eficiente para atender a esses chamados, pois é nomeado um comitê de compliance a quem as dúvidas e denúncias são encaminhadas, para que ele dê vazão a elas rapidamente e as providências necessárias sejam tomadas de forma ágil. Os canais de comunicação devem garantir a confidencialidade e o anonimato das informações, precisam ser um porto seguro para quem vai buscá-los. Quem denuncia um ilícito precisa ter certeza de que não corre risco de ser punido por isso.

A Siemens, por exemplo, disponibiliza em seu site, no mundo todo, um canal chamado Tell us – Canal de Denúncias, em praticamente todas as línguas. Qualquer pessoa no mundo pode fazer uma denúncia pelos canais da Siemens.

Documentação

Tão importante quanto ter o manual de compliance, é documentar tudo o que é feito a partir da implementação dele. Em caso de investigação e condenação da empresa, a simples posse do manual de compliance não é suficiente para a possibilidade de redução na pena, é preciso comprovar a aplicação e a operacionalização desse manual. Todas as atividades ligadas ao manual de compliance devem ser documentadas para o caso de precisarem servir de prova em uma investigação. Todos os procedimentos devem registrados de forma expressa e clara para garantir segurança, confiança e efetividade na implementação do programa de compliance, preservando também a memória institucional. Isso ainda facilita a prestação de contas no caso de uma auditoria e auxilia no processo de revisão do manual, que deve ser constante. Devem ser registradas as diretrizes da instituição em relação ao programa de compliance, os treinamentos, as reuniões com atas assinadas pelos presentes, até com fotos, vídeos e áudios. Exemplo importante: não utilizar e-mail corporativo ou da sociedade para situações pessoais. É necessário registrar também tudo relacionado ao comitê de compliance, resguardando-se a confidencialidade e o anonimato necessários.

Treinamento

Colocar em prática tudo o que foi colocado no papel, unindo toda a equipe, todo o corpo diretivo da empresa. É compromisso ético colocar em prática o que está no manual. Se forem bem efetivos, esses treinamentos podem até ser on-line, não precisam ser sempre presenciais. Podem ser por setores, áreas, por partes da empresa e devem ser repetidos quando entram novos integrantes na sociedade, novos colaboradores.

Monitoramento e atualização do programa

O automonitoramento é importante porque, com ele, vou verificar se as regras estão sendo cumpridas e analisar se devo implementar novas tecnologias, mudar o canal de comunicação, em que posso evoluir. A legislação muda, as condutas mudam e o dia a dia da empresa muda também.

Governança

Organização de todas as funções. A empresa vai atribuir a responsabilidade a um comitê gestor do compliance, que tem que primar por alguns princípios, como transparência, responsabilidade, igualdade, inclusividade, efetividade, eficiência e prestação de contas. Esse comitê precisa ter um poder decisório, autonomia, independência e garantia de cumprimento das orientações, porque vai receber as dúvidas e as denúncias e não pode parar tudo para pedir orientações à alta direção sempre que precisar tomar decisões.

Programa de fachada

Se, em caso de investigação, a autoridade pública verificar que o manual de compliance da empresa não é colocado em prática, não há redução da multa, ao contrário, ela será majorada, porque será detectado um programa de fachada.

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  146. Los Blancos, with captain Sergio Ramos suspended after deliberately collecting a yellow card in the first leg, had been looking to build on a slender 2-1 lead from that game in Amsterdam and stay on course for a potential fourth straight European triumph.

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