Developing and Managing Compliance Policy Documents

Richard P. Kusserow | June 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 the development is done through an outside contractor, law firm, or internally by a 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.

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.