Tips on Developing Compliance Policies and Procedures

Richard P. Kusserow | September 2014

The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) has issued a number of compliance program guidance documents, all of which stress, in turn, the importance of written compliance guidance for employees. The OIG notes that, “At a minimum, comprehensive compliance programs should include … the development and distribution of written standards of conduct, as well as written policies and procedures that promote the [organization’s] commitment to compliance and that address specific areas of potential fraud, such as claims development and submission processes, code gaming, and financial relationships with physicians and other health care professionals.” 1  The United States Sentencing Commission Federal Sentencing Guidelines notes that to “have an effective compliance and ethics program.., an organization shall … establish standards and procedures to prevent and detect criminal conduct.”

About the Author

Richard P. Kusserow established Strategic Management Services, LLC, after retiring from being the DHHS Inspector General, and has assisted over 2,000 health care organizations and entities in developing, implementing and assessing compliance programs.