The OIG and the Healthcare Compliance Association (HCCA) held a roundtable to discuss a broad range of ideas regarding how healthcare organizations can measure their compliance program effectiveness.
These ideas are contained in a document, “Measuring Compliance Program Effectiveness – A Resource Guide,” which addresses both what and how to measure compliance with the standard seven elements of a compliance program:
- Standards, Policies, and Procedures
- Compliance Program Administration
- Screening and Evaluation of Employees, Physicians, Vendors and other Agents
- Communication, Education, and Training on Compliance Issues
- Monitoring, Auditing, and Internal Reporting Systems
- Discipline for Non‐Compliance
- Investigations and Remedial Measures
For example, the guide suggests that organizations can measure third party and non‐employed clinician contracts to ensure they have an obligation to cooperate in investigations. This can be measured by (1) contract review, and (2) inventory of agreements with third parties and non‐employed clinicians to make sure they understand their obligation to cooperate with investigations.
The OIG intends for organizations to select from among the roughly 50-pages of ideas that are most suitable to the organization; the OIG states that it “is impractical and not recommended” to use all or even a large number of these measures in any given year. Moreover, the OIG discourages use of the resource guide as a standard or a certification, since “one size truly does not fit all.”
Lisa Remington is widely recognized as one of the foremost futurists in the home care industry, focusing on healthcare trends and disruptive innovation. She serves as the president and publisher of the Remington Report magazine and is also the President of Remington’s Think Tank Strategy Institute. Lisa provides strategic advice and education to over 10,000 organizations, assisting them in developing transformative strategies for growth and their future implications. She closely monitors complex trends and forces of change to develop effective strategic approaches.
