When was the last time you thought about your compliance program? As we know, an effective compliance program is important for healthcare companies. It’s also important to review your compliance program periodically and update it according to the latest guidance. OIG guidance and recent Corporate Integrity Agreements (CIAs) are informative about what the OIG is currently concerned about.
I recently presented on this issue at the AHLA Fraud and Compliance conference with Mary Riordan, of the OIG, and Thomas Beimers, of Faegre Baker Daniels. At the presentation, we discussed that recent CIAs are emphasizing accountability of individuals and effective monitoring of potential risk areas, and it has been clear that the OIG will take action if an organization does not comply with its CIA.
It is also important to note that even in the absence of a CIA, it is critical for organizations to have an effective compliance program. Given the current enforcement environment, having an effective compliance program can mitigate against a possible civil or criminal action.
Our Insight. Your Advantage. It is important to continually review and revise your compliance program to ensure that it is effectively identifying and addressing potential compliance issues. Recent enhanced CIA provisions, coupled with previous guidance issued by OIG, can serve as useful guides.