Blog Post

Independent Compliance Program Assessments

Richard P. Kusserow | May 2025

The 2025 Compliance Benchmark Survey, conducted by SAI360 and Strategic ย Management Services, LLC, provides insights and understanding of the status and progress of compliance program development in the healthcare industry. As part of the survey, respondents were asked about whether their compliance programs undergo independent evaluations. Both the OIG and DOJ view independent evaluations as key indicators of a compliance program effectiveness. They have made it clear that independent evaluation evidence is far more credible than that which is generated internally. The OIGโ€™s General Compliance Program Guidance of November 2023 specifically advises that an organizationโ€™s Board ensure that compliance program effectiveness reviews are conducted, and that consideration is given to retaining an outside expert to conduct the review. When asked about this, half of the respondents reported having engaged outside experts to assess their compliance programโ€™s effectiveness, with a third reporting that these reviews had taken place within the last three years. The remaining half reported relying on internal evaluations or not conducting any evaluations at all. Elsewhere in the Survey, respondents reported that internally generated evidence typically came from audits/reviews, hotline complaints and investigations, and regulatory/legal reviews.

Interested in learning more? Click the Download PDF button above to read the report or here to watch the webinar. You can also contact Richard Kusserow at [email protected] to discuss support for your Compliance Program.

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.

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