Chapter 2: Healthcare Compliance Program Fundamentals

Essential Elements of an Effective Healthcare Compliance Program

The Office of Inspector General (OIG) offers guidance for healthcare organizations seeking to build effective compliance programs.[4] Their guidance recognizes that there is no one-size-fits-all compliance program. These guidance publications are directed at different segments of the healthcare industry.

Each OIG guidance document outlines seven basic elements that can be tailored to fit the needs and financial realities of any given organization. The OIG believes every effective compliance program begins with a formal commitment to these seven basic elements, which were based on and expanded upon the seven elements described within the Federal Sentencing Guidelines.[5] These seven fundamental elements of an effective compliance program are:

  1. Implementing written policies, procedures, and standards of conduct.

  2. Designating a compliance officer and compliance committee.

  3. Conducting effective training and education.

  4. Developing effective lines of communication.

  5. Conducting internal monitoring and auditing.

  6. Enforcing standards through well-publicized disciplinary guidelines.

  7. Responding promptly to detected offenses and undertaking corrective action.[6]

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