Many health care organizations have developed corporate compliance programs. Once key elements of the compliance plan are established however, the larger challenge becomes monitoring the effectiveness of the program and making necessary modifications to maintain the program's integrity. The following is a list of factors to consider when evaluating the effectiveness of your existing compliance program.
Document Program Effectiveness
Not only has the Office of Inspector General ("OIG") stated that the existence of a Compliance Program will be factored into decisions regarding penalizing providers, but the effectiveness of the program will also be considered. A report from the OIG on the Government Industry Roundtable noted that documentation is the key to demonstrating the effectiveness of a provider's compliance program.
