Time to Schedule the 2026 Compliance Program Evaluation
Conducting a Compliance Program Effectiveness Evaluation early in the year is one of the most strategic decisions a compliance officer can make. It is not about grading past performance, but about positioning the organization for success in the months ahead. By providing clarity, aligning priorities, informing risk planning, and allowing time for meaningful improvement, early evaluations transform compliance from a reactive function into a strategic asset. For organizations committed to sustainable growth, regulatory resilience, and strong governance, there is no better time to evaluate the compliance program than at the very beginning of the year. An independent compliance program evaluation early in the year is not a report card, but a strategic management tool. For healthcare compliance officers, it strengthens program effectiveness, enhances regulatory defensibility, builds leadership confidence, and enables proactive risk management. Ultimately, early evaluation allows compliance officers to lead the year with clarity, credibility, and control rather than reacting to issues after they arise. The following outlines key benefits of commissioning an independent compliance program evaluation early in 2026:
- Meets OIG and DOJ Expectations. The Department of Justice (DOJ) and Office of Inspector General (OIG) consistently emphasize that compliance programs must be effective in practice, not just well-documented. An independent evaluation early in the year demonstrates continuous monitoring and improvement, evidences leadership engagement and accountability, and provides credible evidence of good-faith compliance efforts. For healthcare organizations facing payor audits, government inquiries, accreditation reviews, mergers, acquisitions, or private equity investment, an early independent evaluation provides objective evidence of program maturity risk awareness, which are qualities highly valued by external stakeholders. This also strengthens the organization’s defensibility.
- Starting the Year Proactively. Having an independent third-party evaluation early in the year provides the compliance officer with a clear, objective understanding of the current state of the compliance program. Policies may exist on paper, training may have occurred, and reporting mechanisms may be in place but the question is whether these elements are operating effectively. By assessing program design, implementation, and effectiveness at the outset of the year, organizations avoid relying on assumptions about compliance maturity and instead begin the year with actionable insight into strengths, gaps, and emerging risks.
- Creates Compliance Baseline. An early-year evaluation provides an objective baseline of compliance program maturity and effectiveness. Rather than reacting to issues later, compliance officers can identify gaps and weaknesses before they become enforcement issues; prioritize high-risk areas for the annual compliance work plan; and align compliance initiatives with organizational goals and operational realities. This turns compliance from a reactive function into an initiative-taking, strategic one.
- Evidence of Board and Executive Oversight. Boards and executive leadership increasingly expect meaningful compliance reporting. An early independent evaluation provides actionable insights rather than retrospective reporting, enables tracking of improvements throughout the year, and reinforces the compliance officer’s role as a strategic advisor. This strengthens governance and oversight responsibilities. Boards and compliance committees increasingly expect timely, meaningful insight into compliance program effectiveness, not just activity metrics. An early-year evaluation equips compliance leadership with substantive information to support informed discussions with governance bodies. It also demonstrates that the organization takes compliance oversight seriously and is committed to continuous improvement, a key consideration in enforcement actions, settlement negotiations, and Corporate Integrity Agreements.
- Independence and Objectivity. Internal self-assessments often suffer from bias or operational blind spots. An independent third-party evaluator brings an external benchmark against industry’s best practices; identifies risks internal teams may normalize over time; and provides unbiased and objective findings that carry greater weight with the executive leadership, board, and regulators. This independence enhances the compliance officer’s credibility and influence.
- Supports Budgeting and Resource Allocation Decisions. Recommendations from evaluations are far more persuasive when delivered early in the fiscal cycle. Most organizations finalize budgets, growth initiatives, technology investments, and staffing plans early in the year. A compliance program evaluation conducted at the same time allows compliance priorities to be integrated into those decisions rather than added later as an afterthought. This alignment helps ensure that compliance risks tied to expansion, acquisitions, or new service lines are identified early, resources are allocated where risk is highest, and compliance initiatives support, rather than impede, operational objectives. An early-year evaluation helps leaders make informed decisions about whether additional compliance staff or external support is needed; where targeted training will have the greatest impact; and which technological investments can improve monitoring, reporting, and documentation. Making these decisions early avoids rushed, reactive solutions later.
- Annual Risk Assessment and Work Plan. A compliance program evaluation is not a report card; it is a diagnostic tool. Early-year evaluations provide critical input into the annual compliance risk assessment and work plan by identifying areas where controls are weak or inconsistent, high-risk functions require focused monitoring or auditing, and training gaps that could expose the organization to enforcement risk. This allows compliance officers to build a risk-based work plan that reflects actual organizational needs, rather than last year’s priorities or regulatory checklists. Early identification also allows corrective actions to be incorporated early in the work cycle.
- Allows Time to Address Findings. Conducting the evaluation early leaves adequate time to implement corrective action plans; update policies, training, and controls; and test remediation effectiveness later in the year. Late-year evaluations often identify problems when there is little time to fix them. Identifying gaps early in the year creates the most valuable asset in compliance: time. This reduces the likelihood that identified weaknesses will be compounded by operational changes, regulatory updates, or external scrutiny later in the year.
- Demonstrating Compliance Culture. Regulators consistently emphasize that effective compliance programs are dynamic, risk-based, and actively monitored. Conducting a compliance program evaluation early in the year sends a powerful message internally and externally that compliance is a priority, not a checkbox. It reinforces a culture in which issues are identified and addressed proactively, employees understand expectations, and leadership remains engaged throughout the year.
Interested in learning more? For more information on how to schedule a Compliance Program Evaluation that will help your 2026 off to an auspicious beginning, contact Richard Kusserow at [email protected].
