7 Signs Your Healthcare Compliance Program Needs an Independent Review
Most healthcare organizations believe they have an effective Compliance Program until an audit, investigation, or whistleblower complaint reveals otherwise. An independent review can identify vulnerabilities before they become costly liabilities.
The Department of Justice (DOJ) and Office of Inspector General (OIG) have repeatedly stressed that compliance is an ongoing obligation, not a one-time exercise. To withstand regulatory scrutiny, organizations must actively measure compliance program effectiveness and demonstrate continual improvement. This is exactly why federal regulators strongly encourage periodic, independent healthcare compliance program evaluations.
If you are wondering how the effectiveness of your organization’s compliance program can be determined, keep an eye out for these seven warning signs.
What Should You Do When a Compliance Officer Departs?
The absence of a compliance officer in an organization’s compliance program creates uncertainty and risks regarding compliance priorities, oversight, and accountability. An independent review can help assess the program’s current state and identify immediate areas requiring attention.
When Do Growth and Change Signal Your Compliance Program Needs a Review?
Compliance programs should evolve alongside changing regulations, enforcement priorities, business environment, and organizational risks. In programs that have not been independently assessed in several years, gaps and weaknesses may have developed unnoticed. Mergers, acquisitions, new service lines, geographic expansion, or rapid increases in patient volume can introduce new compliance risks. What may have worked before may no longer be sufficient.
What Do Repeat Audit Findings Signal About Your Compliance Program?
When the same issues continue to appear in auditing or monitoring activities, it may indicate underlying weaknesses in compliance oversight, training, or corrective action processes.
How Can an Independent Review Help Your Board Oversee Compliance?
Healthcare boards face increasing expectations to oversee compliance program effectiveness. An independent evaluation can provide objective information that helps board members fulfill their governance responsibilities.
When Does Regulatory Scrutiny Warrant an External Compliance Review?
Federal and state regulators have intensified their fraud enforcement efforts, particularly for billing accuracy, privacy, quality of care, arrangements with referral sources, and program effectiveness. Organizations operating in high-risk environments should periodically validate that their compliance programs are meeting current expectations.
How Do You Prove Your Compliance Program Is Working?
Having policies, training, and audits is important, but regulators increasingly want evidence of program effectiveness. If leadership cannot confidently demonstrate effectiveness, an independent review can help identify strengths, weaknesses, and opportunities for improvement.
When Should a Compliance Program Be Independently Evaluated?
The best time to evaluate a compliance program is before a problem occurs. An independent review provides objective insight into whether a program is functioning as intended and whether it is capable of withstanding regulatory scrutiny. Organizations that regularly assess their compliance programs are better positioned to manage risk, support board oversight, and strengthen their culture of compliance.
For more information on this topic, contact Richard Kusserow ([email protected]).
