Corporate Compliance

Tip: Audit compliance program to determine effectiveness

Healthcare Auditing Weekly, December 2, 2008

The OIG believes an ongoing evaluation process is critical to a successful compliance program. Compliance officers should monitor the program during its implementation and regularly report to senior or corporate officers. Compliance reports created by this ongoing monitoring, including reports of suspected non-compliance, should be maintained by the compliance officer and shared with senior management and the compliance committee. The OIG recommends these audits and reviews should include the following:
  • Focus on all programs or divisions, including external relationships with third-party contractors, specifically those with substantive exposure to government enforcement actions
  • Be designed to address compliance with law governing kickback arrangements, coding, claim development and submission, reimbursement, cost reporting, and marketing
  • Address compliance with specific regulations, rules and policies
  • Include monitoring techniques such as sampling protocols that create a baseline audit of items and services, with provisions to identify and act on significant variations from the baseline
  • Include periodic reviews to determine if the compliance program’s elements have been satisfied
  • Include on-site visits, interviews with key people in management, operations, and coding
  • Use employee surveys designed to solicit impressions of a broad cross-section of staff members
  • Review medical/financial records and other source documents that support claims for reimbursement.
  • Engage in trend analyses/longitudinal studies that seek deviations from established patterns
This tip is adapted from The Healthcare Compliance Professional’s Guide to Policies and Procedures. For more information about the book or to order your copy, visit HCMarketplace.

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