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For years, the government has been touting the importance of healthcare organizations having an "effective" healthcare compliance program. The U.S. Department of Justice (DOJ) has issued a 25-page document on what it expects to see when prosecutors evaluate the effectiveness of a compliance program in a government investigation – Evaluation of Corporate Compliance Programs. Additionally, the U.S. Department of Health and Human Services-Office of Inspector General (HHS-OIG) has issued a 91-page general guide to compliance risks and compliance programs specifically for the healthcare industry – General Compliance Program Guidance (GCPG) – and is in the process of updating guides for specific healthcare industry segments – Industry Segment-Specific Compliance Program Guidance (ICPG).
You've probably heard about the seven elements of an effective healthcare compliance program:
- Written Policies and Procedures
- Compliance Leadership and Oversight
- Training and Education
- Effective Lines of Communication and Disclosure Program
- Enforcing Standards: Consequences and Incentives
- Risk Assessment, Auditing, and Monitoring
- Responding to Detected Non-Compliance and Developing Corrective Action Initiatives
Does this all start to make your head hurt? Are you asking yourself what all this means? Are you wondering how you really know if you have an effective compliance program? Click here to access our checklist of questions to help start the process of evaluating the effectiveness of your organization's healthcare compliance program.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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