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Measuring Compliance Program Effectiveness

Measuring compliance program effectiveness is recommended by several authorities, including the United States Sentencing Commission (see, Chapter 8 of the United States Sentencing Guidelines). The Compliance Department is not permitted to perform these audits. Audits must be performed independently, to avoid self-policing. https://www.cms.gov/Medicare/Compliance-and-Audits/Part-C-and-Part-D-Compliance-and-Audits/Downloads/Element-VI-Focused-Training-Power-Point-.pdf. However, it has been reported that only 25 percent of surveyed organizations reported using outside experts to evaluate their program, and nearly 66 percent of organizations claimed that they rely upon self-assessment tools and checklists to evidence their compliance program effectiveness.

On January 17, 2017, the Department of Health and Human Services, Office of Inspector General (OIG) addressed ways to measure the effectiveness of compliance programs. https://oig.hhs.gov/compliance/compliance-resource-portal/files/HCCA-OIG-Resource-Guide.pdf. The critical review necessary to ensure compliance programs address the fluid nature of health care risk is the best means to promote effective compliance and mitigate the opportunity for a state or federal audit.

Trusiak Law can assist you in measuring the effectiveness of your compliance program. It will be done under client/attorney privilege to avoid unnecessary disclosure. If you are interested in learning more about the way in which Trusiak Law may assist you, please contact us.

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