For those of us who refer to ourselves as compliance professionals and work toward the creation, maintenance, and enhancement of compliance programs that conform to the Health and Human Services Office of Inspector General’s (OIG’s) seven elements of an effective compliance program, it is sometimes easy to slip into a mind-set where the development of the program becomes almost prescribed. Sometimes, the task of implementing and overseeing the program seems almost rote. As a chief compliance officer, I recall taking periodic inventories to confirm that my team was still meeting all seven elements and that we were confident that we were apprised of new risks and new changes in the regulatory environment.
The continuous task of assessing new risks, testing controls, and auditing is both necessary and valuable to effective compliance program management, but I continually believed and believe to this day that an effective compliance program offers more than just the seven elements. Put another way, an effective compliance program is worth more than the sum of its parts.
In a time when many of our employers, clients, or customers are going through great change in terms of shifts away from fee-for-service remuneration to models based upon shared risk, or as previously independent organizations merge, it became apparent (to me) that there was an opportunity for compliance programs to not only be the support system that ensures the laws, rules, and policies are being followed, but these programs can also provide a strategic and competitive advantage for organizations in these paradigm shifts. In many cases, these advantages do not represent any major additional work; instead, these advantages come from focusing on work product and existing information in different ways.
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The views expressed herein are those of the author(s) and not necessarily the views of Ankura Consulting Group, LLC., its management, its subsidiaries, its affiliates, or its other professionals. Ankura is not a law firm and cannot provide legal advice.
This article was originally published in Compliance Today magazine. Copyright 2019 Compliance Today Magazine, a publication of the Health Care Compliance Association (HCCA).