Budgets are one way healthcare organizations can demonstrate to regulators their compliance programs are adequately resourced.
For the last several years, the Office of Inspector General (OIG) and the Department of Justice (DOJ) have published guidance focusing on compliance program resources and how they tie to effectiveness.
In June 2020, the DOJ discussed the importance of scaling compliance program resources to match the size and complexity of the organization and its risk profile. In its guidance, the DOJ suggests prosecutors should evaluate the “resources the company has dedicated to compliance.” Resources not only include sufficient staffing to “effectively audit, document, analyze, and act on the results of the compliance efforts” but also sufficient funds to carry out the work. The guidance also advises prosecutors to inquire whether there have been times when “requests for resources by compliance and control functions have been denied, and if so, on what grounds.”