The OIG and the Health Care Compliance Association (HCCA) recently held a roundtable where the discussion focused on a broad range of ideas regarding how health care organizations can measure their compliance program effectiveness – while stressing that each organization must tailor its compliance program to reflect the organization’s specific circumstances. These ideas are contained in a document, “Measuring Compliance Program Effectiveness – A Resource Guide,” which addresses both what and how to measure compliance with the standard seven elements of a compliance program:

  • Standards, Policies, and Procedures
  • Compliance Program Administration
  • Screening and Evaluation of Employees, Physicians, Vendors and other Agents
  • Communication, Education, and Training on Compliance Issues
  • Monitoring, Auditing, and Internal Reporting Systems
  • Discipline for Non‐Compliance
  • Investigations and Remedial Measures

For instance, with respect to the seventh element (investigations), the guide suggests that organizations can measure third party and non‐employed clinician contracts to ensure they have an obligation to cooperate in investigations. This can be measured by (1) contract review, and (2) inventory of agreements with third parties and non‐employed clinicians to make sure they understand their obligation to cooperate with investigations.

The OIG intends for organizations to select from among the roughly 50-pages of ideas that are most suitable to the organization; the OIG states that it “is impractical and not recommended” to use all or even a large number of these measures in any given year. Moreover, the OIG discourages use of the resource guide as a standard or a certification, since “one size truly does not fit all.”