On March 27, 2017, the Department of Health and Human Services, Office of Inspector General (“OIG-HHS”), in collaboration with the Health Care Compliance Association (HCCA), published Measuring Compliance Program Effectiveness – A Resource Guide (the “Guide”). The Guide was based on a series of discussions between healthcare compliance professionals conducted in January of this year to provide meaningful guidance and best practices for assessing the effectiveness of organizations’ compliance programs, which is recommended by the United States Federal Sentencing Guidelines.
In one form or another, several governmental entities over the years have outlined the elements of an effective compliance program, which can be summed up as follows: (1) written policies and procedures, (2) compliance program oversight, (3) screening of ineligible persons, (4) training and communication, (5) monitoring and auditing, (6) appropriate enforcement of non-compliance, and (7) responding promptly and undertaking corrective action. The Guide represents the first regulatory guidance by OIG-HHS to provide specific details and examples of how and what can be measured to assess the effectiveness of compliance program elements.
If you have questions about how your organization can evaluate the effectiveness of its compliance program or have matters that warrant the involvement of outside accountants or consultants, please contact Patrick Braley or Chris Roane by calling 770.396.2200.