Hospitals, health systems, physician groups and other healthcare industry face an enormous regulatory and compliance burden unlike any other sector. Below, Womble Bond Dickinson Healthcare Consultant Carrie Tuttle discusses the Office of Inspector General’s (OIG’s) Seven Elements of an Effective Compliance Program. These elements can serve as guideposts to help healthcare providers and employers create a culture of compliance and proactively address compliance shortcomings that may lead to problems down the road.

Also, watch below to see a comprehensive webinar presentation with Tuttle discussing the elements of an effective compliance program in the healthcare industry.


Implementing Policies, Procedures, and Standards of Conduct
Policies, procedures, and standards of conduct should be written in such a way that is easily understood in order to maintain compliance while performing job functions.  Policies and procedures should be clearly written, they should be relevant and current, specific to job functions, reviewed on a regular basis (e.g. monthly or quarterly), and readily available.

Designating a Compliance Officer and Compliance Committee
Designating a Compliance Officer and Compliance Committee will at minimum prevent, detect, and correct non-compliance, supports the organization’s unique structure and compliance program with sufficient resources, promotes standards of conduct, and establishes a clear means of communication for reporting non-compliance.

Training and Education
Effective training and education can be achieved by offering compliance training frequently (at minimum annually), making training and education part of the job requirements, and staying current on compliance issues and trends by attending conferences, reading articles and/or publications, and professional networking.

Effective Communication
Developing effective lines of communication is essential and is a great mechanism for reporting instances of potential non-compliance. Effective communication can be developed by being visible and approachable, ensuring confidentiality, communicating the compliance message, encouraging feedback, and providing methods for anonymous and good-faith reporting (e.g. anonymous hotline, survey, etc.).

Monitoring and Auditing
Conduct internal monitoring and auditing by establishing an annual work plan, determine any areas of risk, proactively audit, and review the compliance program.  This ensures the compliance program addresses any areas of concern while sustaining compliance program effectiveness.

Disciplinary Guidelines
Well-published disciplinary guidelines ensure standards are followed continuously and consistently throughout the organization.  Standards should be followed by all personnel regardless of position, title, or rank.  Never assume the standards are being followed, check in often to inspect for the standards set forth.
Detecting Offenses and Corrective Action
Developing a method for tracking and responding to compliance issues, thoroughly documenting and investigating, enforcing corrective action, and tracking the resolution of complaints are effective ways to address offenses. Acting promptly to detected offenses and undertaking the appropriate corrective action is pertinent to maintaining an effective compliance program.