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How to Measure Compliance Program Effectiveness

December 18, 2018
Compliance By Rodney Farley, Director

An effective compliance program is critical for healthcare organizations because it helps to reduce fraud and abuse, enhances healthcare provider operations, improves the quality of services, and reduces overall costs. The Department of Health and Human Services and Office of Inspector General (OIG) has developed "Measuring Compliance Program Effectiveness: A Resource Guide" to assist organizations with their compliance efforts. You can also learn more by reading our current blog series "7 Elements of an Effective Compliance Program."

Doctor working with  laptop computer in medical workspace office and medical network media diagram as concept


The resource guide has a compilation of ideas for measuring the following elements of a compliance program:

  • Standards, policies, and procedures
  • Compliance Program Administration
  • Screening and evaluation of employees, physicians, vendors and other agents
  • Communication, education, and training on compliance issues
  • Monitoring, auditing, and internal reporting systems
  • Discipline for non-compliance
  • Investigations and remedial measures

These compliance efforts should be based on each organization’s specific needs and will differ depending on the organization’s greatest risks or potential concerns, including the organization's size, resources and industry segment. 

The OIG has made it clear that the resource guide should not be used as a checklist because it is impractical for an organization to attempt to use all of the ideas that are listed. 

The Centers for Medicare & Medicaid Services (CMS) has also released new regulations for Long Term Care Facilities. These regulations can be found in their "State Operations Manual," section 483.85-Compliance and Ethics Program. CMS defines a compliance and ethics program as “a program of the operating organization that; has been reasonably designed, implemented, and enforces so that it is likely to be effective in preventing and detecting criminal, civil, and administrative violations under the Act and in promoting quality of care.”

It is important for organizations to stay up to date with regulations and laws so that they can continue to improve their compliance program as necessary. 

LW Consulting, Inc. can review your organization's current compliance program and develop a plan to improve ongoing monitoring of your compliance practices. For more information, contact Rod Farley, Director at 717-213-3123 or email RFarley@LW-Consult.com.

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