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OIG Issues Resource Guide For Measuring Effectiveness of Corporate Compliance Programs

On March 27, 2017, the Office of the Inspector General ("OIG") posted a Resource Guide for Measuring Compliance Program Effectiveness. You can access the OIG's Guide here. The Guide is organized under the following "elements" that should be addressed under an organization's Compliance Program:

· Element 1: Standards, Policies, and Procedures

· Element 2: Compliance Program Administration

· Element 3: Screening and Evaluation of Employees, Physicians, Vendors

and other Agents

· Element 4: Communication, Education, and Training on Compliance Issues

· Element 5: Monitoring, Auditing, and Internal Reporting Systems

· Element 6: Discipline for Non‐Compliance

· Element 7: Investigations and Remedial Measures

Under each Element, the OIG gives examples of how to measure your plan's effectiveness in addressing compliance issues affecting health care providers.

We recommend that providers (and their Compliance Officers) carefully review the OIG Guidance as a means of measuring the effectiveness of their Compliance Programs. To the extent that your current Program or operations do not address some of the Elements identified by the OIG, we recommend modifying the Program to do so.

If you would like assistance in your evaluation or modification of your current Compliance Program, or have questions regarding the OIG's Guidance, please do not hesitate to contact David Marshall at (717) 620-2424.

Here's the link:

https://oig.hhs.gov/compliance/101/files/HCCA-OIG-Resource-Guide.pdf

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