When To Have Independent Compliance Evaluations
For most organizations, the ideal time to have evaluations is early in the fiscal year
Independent compliance program evaluations by outside experts are important because they provide an objective and unbiased assessment of how effectively a healthcare organization’s compliance program is designed, implemented, and functioning. Both the Department of Health and Human Services (HHS) Office of Inspector General (OIG) and the Department of Justice (DOJ), in their respective guidance and guidelines, expect organizations to periodically conduct independent compliance program evaluations. The OIG specifically recommends periodic independent reviews as a best practice. During investigations or settlements, the DOJ and OIG often look for evidence that an organization’s compliance program has been independently assessed.
The OIG and DOJ stress that compliance must be a top-down program beginning at the board level. Boards are expected to be actively involved in ensuring that independent evaluations occur. As such, it is in the interest of boards to commission these evaluations and review the results to evidence fulfillment of their oversight, fiduciary, and legal responsibilities. A key question for many organizations is when to conduct the evaluation. Over the last 30 years, Strategic Management Services has conducted hundreds of these evaluations and has found that completing them early in the year, whether the calendar year or the organization’s fiscal year, produces the most beneficial results. The following are five reasons why early-year evaluations are optimal:
- Most healthcare organizations develop their annual compliance work plan and risk assessment at the start of the year. An early evaluation allows the findings and recommendations to be incorporated into this process and ensures adequate resources are available to address the identified deficiencies and risks.
- Boards and Executive Compliance Committees often review compliance performance early in the year. A fresh, independent assessment gives leadership timely insights to set priorities and demonstrate accountability.
- Results from an early-year assessment can identify the need for additional resources, such as training, monitoring tools, or corrective actions, and ensure that necessary improvements can be funded and implemented within the same fiscal year.
- Conducting assessments early in the year evidence that compliance is a priority and part of ongoing enhancement, not an afterthought. This reinforces a culture of continuous improvement and diligence among regulators and staff.
- Receiving results early in the year allows the Compliance Officer to evidence the progress of the compliance program, while addressing identified weaknesses and opportunities for improvement or enhancement.
Interested in discussing your compliance program and how our Compliance Experts might be able to help? Connect with us and let’s set up a meeting.
