Measuring and Benchmarking Compliance Program Effectiveness

Richard P. Kusserow | June 2013

One of the best, but least utilized, tools for evaluating compliance program effectiveness is the use of employee surveys; not just any surveys but tools designed to provide reliable, valid, and credible results. There are a lot of authorities that advocate their use in providing measurable evidence of compliance efforts of an organization are proceeding.

The U.S. Department of Health and Human Services (HSS) office of Inspector General (OIG) in its compliance guidance documents calls for benchmarking and evidencing compliance program effectiveness. Benchmarking and evidencing effectiveness are closely related concepts but are worth differentiating. The term effective, in its root and various forms, is used 19 times in the original Compliance Program Guidance for Hospitals. Anytime a government agency emphasizes a term or concept throughout a document you can be certain that the agency places a high value on such term or concept. On the other hand, the OIG calls for benchmarking the compliance program progress but provides only little guidance with regard to proper benchmarking techniques.

About the Author

Richard P. Kusserow established Strategic Management Services, LLC to assist health care organizations develop, implement and assess compliance programs. Mr. Kusserow has worked with health care organizations to conduct compliance program effectiveness evaluations, deliver advisory services, develop policies and procedures and deliver compliance and internal investigations training.