Seven elements of OIG compliance program
While the model compliance plan developed by the Office of the Inspector General (OIG) of the Department of Health and Human Services in Washington, DC, may undergo changes before release, the OIG has made clear what it considers the seven core elements. This a preview provided by John C. West, JD, MHA, and John Steiner, JD, both assistant legal counsel with the American Hospital Association in Chicago:
1. Compliance standards and procedures
• General statement of conduct
• Written policies and procedures
• Updates for regulatory change and current events
• Communication to all employees and other agents
2. Oversight responsibility
3. Effective training and education
• To all employees and other agents
• Participation required, with document attendance
• Topics must include regulations, ethics, and compliance using a variety of methods
• Periodic review and updates to programs
4. Monitoring and auditing system
• Ongoing monitoring of the compliance plan
• Use of internal and external reviews
• Focus on identified risk areas
• Regular reporting to management and effective follow up
5. Effective lines of communication
• Publicized reporting system for employees and other agents
• No fear of retribution
• Policies, procedures, and reporting processes that are promoted
6. Enforcement and discipline
• Written policy of progressive discipline
• Consequences consistently applied
• Program monitored for effectiveness and refined accordingly
7. Response and prevention
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