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Generative questions can improve compliance committee effectiveness

Margaret Hambleton (margaret@hambletoncompliance.com) is President of Hambleton Compliance, LLC in Valencia, CA.

The OIG expects an organization’s compliance committee to advise and support the compliance officer in fulfilling their responsibilities. The expectation is that the compliance committee will do this by evaluating the effectiveness of the compliance program, assisting in the analysis of risk areas and helping oversee monitoring of internal audits and investigations. Interestingly, it is pretty rare that I see the compliance committee providing much advice or support to the compliance officer. In most cases, the compliance officer simply reports the activities from the compliance department that occurred since the last meeting. Little input comes back to the compliance officer from committee members. Rather than advice and support, these compliance committee meetings do little more than check the box that this element is in place.

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