The Office of Inspector General recently released Measuring Compliance Program Effectiveness: A Resource Guide, a new resource to assist organizations with their compliance efforts. The guide provides organizations with a host of ideas as to what and how to measure the effectiveness of all seven elements of a compliance plan. The guide allows providers to select the ideas that work best for their program. The OIG cautioned that the guide is not intended to be applied as a template.
The OIG has long encouraged physicians to implement compliance programs, consisting of seven specific elements, and to measure the effectiveness of these programs. The guide comes on the heels of the Department of Justice release of “Evaluation of Corporate Compliance Programs,” which is a long list of questions that prosecutors will ask when deciding whether to file fraud charges against corporations and/or individuals and what kind of charges to bring.