Developing and Managing Compliance Policy Documents: Always Use Caution When Developing Documents for Your Organization

Richard P. Kusserow | May 2014

Developing, implementing, and disseminating written compliance documents is a major foundation of any compliance program, both in terms of organization and management of the program. The documents should include the code of conduct and a myriad of policy documents for both the management and operation of the compliance program, as well as compliance with applicable laws, regulations, rules, and standards.  Unfortunately, the time and cost of developing a policy averages about $5,000 or more, regardless of whether development done through an outside contractor, law firm, internally committee or any combination thereof. If care is not taken, this can be a costly, time-consuming, and distracting endeavor. Properly referencing and linking policy documents is a significant effort by itself. Also, consideration must be given to the resources expended to sufficiently review and approve policy documents to be consistent with other related policies and all applicable laws and regulations.

It is not surprising, therefore, that many seek shortcuts, such as using policy documents prepared by another organization or ones found on the Internet. Some organizations post many of their policy documents online and are free to download. Care must be taken when using this approach in that there may be significant differences in type of organization and management in the way the policy and procedures are set forth. There is also some risk as to whether the copied policy was properly developed, referenced, cited in laws/ regulations, and interpreted correctly.

Simply put, another organization may not have done a sufficient job addressing the issue in terms of compliance with applicable rules and regulations. If not, there is the risk of taking on the results of that company’s mistakes. In short, copying someone else’s product may lead to problems and potential liability; however, with that said, there are legitimate and authoritative sources available to assist in developing policy documents that provide proper citation and referencing. This may prove to be an efficient, effective, and inexpensive solution to policy development. [1]

[1] For more guidance, see Policy Resource Center at

About the Author

Richard P. Kusserow established Strategic Management Services, LLC, after retiring from being the DHHS Inspector General, and has assisted over 3,000 health care organizations and entities in developing, implementing and assessing compliance programs.