Corporate Compliance

Tip: Use the New York model to develop a compliance program

Compliance Monitor, March 23, 2011

Facilities without compliance programs should look to implement them. New York has a mandatory compliance program model already in place, and the federal government is in the process of crafting its own version, required by the Patient Protection and Affordable Care Act, signed into law March 23, 2010.

While it's still not clear what that model will look like, organizations would be wise to look at what's been done in New York because elements may be similar. Compliance programs in New York must meet the following eight requirements:

  • Create written policies and procedures
  • Designate a compliance officer
  • Provide training and education
  • Ensure solid communication for reporting
  • Create effective disciplinary policies
  • Establish a system to identify compliance risk areas
  • Create a means to respond to compliance issues
  • Provide a policy that protects against intimidation and retaliation

To help organizations meet these goals, New York has developed a Compliance Program Assessment Tool, which can be accessed at

This tip was adapted from the April 2011 issue of Strategies for Health Care Compliance. More information about Strategies for Health Care Compliance is available at the HCMarketplace.

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