On March 27th, the Department of Health and Human Services, Office of Inspector General (OIG) released a new resource guide, “Measuring Compliance Program Effectiveness”. This document (https://oig.hhs.gov/compliance/101/index.asp#measuring) is the result of a meeting in January where compliance professionals and OIG staff met to discuss measuring compliance program effectiveness. This resulting document provides an example list of measurement options to “a wide range of organizations with diverse size, operational complexity, industry sectors, resources, and compliance program.” As with all OIG compliance guidance, this is not a “checklist” to be used “wholesale” but rather a resource to use and determine which ones best suit the organization’s needs. The resource is based on the Health Care Compliance Association’s CHC Candidate Handbook: Detailed Content Outline.
I am positive this will be the new buzz word for 2017 and you will hear plenty about this. Here is what you can do to get ahead of the curve and well on your way to measuring the effectiveness of your compliance program:
- Review the list to see how comprehensive it is
- Put the items in a useable format (spreadsheet)
- Choose a focus area or several items from each element to focus on for the year
- Educate your board and leadership on what compliance program effectiveness means
- Create an annual employee survey of your compliance program, using several of the items and your own questions
- Choose several items to audit and determine the scope
- Review the survey and audit results
- Plan for continuous improvements and future measurements
Becoming familiar with this resource as well as the OIG Compliance Program Guidance for your specific area of the healthcare industry will assist you in proving the effectiveness of your compliance program.
Written by Aurae Beidler, MHA, RHIA, CHC, CHPS