Ineffective Compliance Programs

There are eight common compliance program failures that the government would view as evidence of an “ineffective compliance program,” which in turn results in increased fines, penalties, and settlement terms. The U.S. Sentencing Guidelines for effective compliance programs was first adopted in 1991 and has been updated frequently thereafter. (1) The Office of Inspector General (OIG) followed with a number of compliance guidance documents (2) relating to specific health care sectors. The result has been that compliance programs have taken root in the health care sector and most organizations have built programs to one degree or another that follow the guidance.

1. www.ussc.gov/guidelines/archive
2. oig.hhs.gov/authorities/docs/cpghosp.pdf

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.