Chapter 7. Monitoring, Auditing, and Internal Reporting Systems

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Chapter 7. Monitoring, Auditing, and Internal Reporting Systems

An effective compliance program involves constant evaluation and improvement. To keep improving your program, risk areas need to be consistently monitored and audited. These processes are a compliance program’s detection mechanisms, and they can assist you in finding new risks or detecting ones that have escalated. Additionally, auditing and monitoring can verify that management has put mechanisms in place to mitigate previously identified risks. A reporting system is also necessary for staff to use if they encounter instances of noncompliance and are not comfortable raising issues with management. The reporting system is the safety mechanism for an employee to feel free to raise issues without fear of retaliation or retribution. Having these tools and processes in place demonstrates an organization’s commitment to continually improving its compliance program.

While an expectation of 100% compliance is an ideal goal, it is also unrealistic since organizational compliance relies on everyone’s compliance and accountability. The key is to strive for and demonstrate a process for continually improving and evolving your compliance program and its activities. To that end, you’ll find a strong emphasis on the importance of evaluation in the most recent regulatory agency settlements.

Regular monitoring is an ongoing need. Management should monitor the risks of the organization and ensure that they are mitigated. Monitoring helps to identify early on if risks are escalating so that they can be addressed quickly and reprioritized when needed. Moreover, all OIG compliance program guidance state that ongoing evaluation is critical to a successful compliance program. Regulators (such as the DOJ and HHS OIG) have also identified key areas they look at when evaluating the effectiveness of compliance programs.

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