Chapter 3: Running an Effective Compliance Program

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Conduct an Organizational Compliance Assessment

To begin designing or enhancing your organization’s compliance program, it is important to understand the maturity of the compliance program. As an initial step, compliance officers should obtain feedback from key stakeholders including management and the board of directors and/or its applicable committee. It also is important to obtain feedback from key departments such as Finance, Operations, Procurement, Legal, Information Technology, Audit, Risk, Quality, Human Resources, Marketing and physician leadership.

It is common to complete an assessment of the compliance program against a government issues checklist. For example, Health Care Compliance Association (HCCA) and the Office of Inspector General (OIG) issued a compliance effectiveness resource guide and sample checklist.[4] It is also important to check your state’s guidance with regards to compliance effectiveness. For example, New York’s Office of Inspector General issues guidance on what it expects to see in a compliance program. These checklists help organizations identify if there are gaps in their compliance program.

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