The federal Health and Human Services’ Office of Inspector General (OIG) has recently circulated a new resource guide for compliance, titled “Measuring Compliance Program Effectiveness.” Beyond reciting the seven elements of an effective compliance program, this guidebook provides concrete metrics for “what to measure” and “how to measure” compliance under each element, including for instance performing a fraud risk assessment.

The OIG is careful to remind the health care community that there is no “one size fits all” compliance plan, and that this latest guidance is not meant to serve as a checklist or substitute for a program particularized to the organization’s particular needs and industry risks. Nevertheless, the guidance can serve as a useful platform for building out an effective compliance program and for evaluating and enhancing a program already in place. Performing a compliance review with the Guide as a tool can also help demonstrate a provider’s or health plan’s commitment to compliance “best practices.”