On March 27, 2017, the HHS Office of Inspector General (OIG) issued a document entitled “Measuring Compliance Program Effectiveness: A Resource Guide.” Published in conjunction with the Health Care Compliance Association (HCCA), the Resource Guide stems from a January roundtable discussion involving OIG staff and compliance professionals attending an HCCA conference. There, OIG participants were split into groups and asked to suggest ideas about “what to measure” and “how to measure” with respect to seven elements of a compliance program:
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Standards, Policies, and Procedures;
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Compliance Program Administration;
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Screening and Evaluation of Employees, Physicians, Vendors, and other Agents;
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Communication, Education, and Training on Compliance Issues;
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Monitoring, Auditing, and Internal Reporting Systems;
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Discipline for Non-Compliance;
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Investigations and Remedial Measures.
The OIG states that the purpose of the Resource Guide is “to give health care organizations as many ideas as possible, be broad enough to help any type of organization, and let the organization choose which ones best suit its needs.” Thus, the OIG cautions against a “checklist” approach to using the guide, noting that it did not intend to create a “one-size-fits-all” framework for compliance.
However, the Resource Guide does offer valuable insight for healthcare organizations seeking to measure the effectiveness of their compliance programs. As the most comprehensive presentation of the OIG’s perspective on compliance program effectiveness, the Resource Guide should serve as a starting point for any healthcare organization seeking to build or measure its compliance program.
