Although every entity will have different compliance needs and must tweak their programs as necessary, the HHS Office of Inspector General’s new guide, Measuring Compliance Program Effectiveness: A Resource Guide, provides areas of measurement for programs. This guide was developed out of a roundtable meeting between the OIG and the Health Care Compliance Association (HCCA) (OIG Report, March 27, 2017).
Usefulness. The guide warns that an organization should not use all or even a large number of compliance program metrics provided in the guide, and is not intended to be a checklist. It is also not intended to be used as a standard or certification. At HCCA’s 2017 Compliance Institute, HCCA CEO Roy Snell noted that every compliance organization can make use of something in the guide, but that following every aspect of the guide would be overwhelming for a program and that not every section will be applicable. HHS Inspector General Daniel Levinson followed Snell, calling the guide a "game changer."
Content. The guide begins with a basic element that includes standards, policies, and procedures. This section recommends regular reviews of procedures and controls to ensure that they are comprehensive, listing areas of oversight that programs may not have thought to govern. Next comes an element covering a compliance program administration, including budgetary concerns, the necessity of outside help, a work plan, and ensuring that other departments are properly educated. Other elements cover screening employees and those in other relationships with the entity, training, auditing, and discipline.
Companies: Health Care Compliance Association
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