Spring is a time for renewal. Cleaning out your home, refreshing your life and at work, reassessing your compliance program to ensure that it is operating effectively and efficiently. As federal and state governments continue to escalate enforcement across the board, now is the perfect time. It seems that we are emerging from the COVID-19 pandemic to a changed landscape for compliance programs– that have gone by the wayside, have fewer headcounts, less budget, or worse, all three.
The Office of Inspector General has published a new, interactive General Compliance Program Guidance (GCPG)1, including updates to the original documents that were published years ago.2 The expectation is that the government will follow this up with additional industry segment-specific compliance program guidance (ICPG) in the upcoming months. We anticipate that they will update ICPGs for each sector that is currently out there and add more.
Not only is it a great idea for you to assess your program internally, but I also suggest that you have an independent, third-party assessment of your internal program no less than every three to five years. The independent assessment offers you:
- An unabridged review of your internal program by experts in the healthcare compliance field who can look at your program through an independent lens;
- External assessments can provide your program with suggestions of best practices of what the entity has seen at other organizations;
- Communication of the needs of your program by subject matter experts to your Board and Executive Leadership that is sometimes heard in a different way than when you communicate the same issues;
- Evidence of your commitment to compliance if ever audited by a governmental entity; and
- Overall suggestions for how to make your programs more effective and efficient.
Sources:
1 https://oig.hhs.gov/compliance/general-compliance-program-guidance/
2 https://oig.hhs.gov/compliance/general-compliance-program-guidance
