If you’re in the process of negotiating a Corporate Integrity Agreement (CIA), you need Compliance Experts who can provide actionable insights to help you meet your compliance obligations. Strategic Management has over 25 years experience in healthcare compliance and has the expertise needed to create a work plan and oversee your corporate compliance efforts.
Healthcare Compliance Experts Go Beyond Evaluating The Compliance Program
For decades, the OIG has advised that an effective compliance program begins at the top with the Board and flows down through the executive leadership and Compliance Officer to all employees. The OIG and American Health Lawyers Association (AHLA) issued three communications that underscore the duties and responsibilities of the Board in overseeing an organization’s compliance program. The first was in 2003, “An Integrated Approach to Corporate Compliance: A Resource for Health Care Organization Boards of Directors”, followed in 2007 with “Corporate Responsibility and Health Care Quality: A Resource for Health Care Boards of Directors”. The most recent publication was published in 2015, entitled “Practical Guidance for Health Care Governing Boards on Compliance Oversight”. It was developed in conjunction with the AHLA, HCCA, and the Association of Healthcare Internal Auditors (AHIA). The Practical Guidance clearly promoted the use of independent Compliance Experts by Boards and organizations to assist in evidencing an effective compliance program. It goes further in stating that Compliance Experts can assist Boards and management in a variety of ways beyond evaluation of the compliance program, including identification of high risk areas, insight into best practices in governance, and consultation on investigation or other substantive matters. They advise that Boards should look to ensuring they have compliance expertise available to make sure they meet all of their fiduciary duties and obligations in overseeing Corporate Compliance, whether or not, a Corporate Integrity Agreement (CIA) is involved.
Corporate Integrity Agreement (CIA) Mandated Use Of Healthcare Compliance Experts
As noted in the “Practical Guidance for Health Care Governing Boards on Compliance Oversight“, the OIG has moved to enhance provisions in CIAs that increase oversight and accountability of those who agree to settlement terms. It was particularly significant in that they provided insights about their thoughts about the need for Boards to engage independent Compliance Experts to assist them in meeting their fiduciary obligations. The Practical Guidance provides almost identical language about Boards use of Compliance Experts from this Practical Guidance as they do in CIA today. The OIG urges Boards to use the advice of experts in fulfilling their duties. The OIG has been very clear that they were sometimes requiring entities under a CIA to retain an expert to assist the Board in fulfilling its Compliance Program oversight responsibilities under the CIA.
Any Compliance Expert engaged by an organization must be independent and certify that they will adhere to the independence and objectivity standards of the General Accountability Office “Generally Accepted Government Audit Standards” for operational reviews. All Compliance Experts must have expertise in Federal health care program compliance requirements. Once engaged they, are obligated to create a work plan and then conduct a review that results in a Compliance Program Review Report. The Report focuses on the mandated review and recommendations. A copy of the Compliance Expert Report must be included in each Annual Report under the CIA. Copies of materials provided by the Compliance Expert to the Board and minutes of meetings with them are to be made available to OIG upon request.
Strategic Management Has Unparalleled Expertise, Qualifications And Experience
Strategic Management’s Compliance Experts have been assisting healthcare clients for over 25 years. We have worked with over 2,000 healthcare providers and have conducted more than 500 compliance program reviews. All of the firm’s consultants have engaged in compliance program effectiveness reviews. Strategic Management uses the Comprehensive Compliance Program Evaluation Protocol©, developed and enhanced for over twenty years, to measure over 150 factors affecting compliance program effectiveness. We also utilize the Compliance Knowledge Survey©, which measures effectiveness through a validated and independently administered employee survey.
When OIG Corporate Integrity Agreements began mandating organizations to engage independent Compliance Experts, Strategic Management was among the first firms selected by Boards to assist them in meeting this mandate. Having such extensive experience with federal healthcare regulations, Strategic Management is able to assist organizations with meeting the important deadlines imposed by their CIA and develop timely and credible Compliance Expert Review Reports. This experience enables Strategic Management to provide Compliance Expert services in an efficient and cost-effective manner.
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