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OIG Element #4: Communication, Education, and Training on Compliance Issues

Communication:

Today, we are going to discuss communication as outlined in the OIG guidelines. We will work on Education and Training in the next blog.

Measures of Effectiveness in a Compliance Program:

Below, is the list that was outlined on January 17, 2017 of what the team believed was important in the communication process of Element #4.

  1. The organizations performance appraisals and job descriptions include the requirement for employees to promote compliance.
  2. Employees at all levels of the organization can articulate the compliance/ethics message.
  3. The compliance department/staff regularly present compliance program information and updates at staff meetings, department meetings, board meetings and any other forums necessary.
  4. The organization ensures there is adequate two-way communication between the compliance department staff and employees in order to report concerns.

How to Measure

The report has many suggestions on how to measure these four points, and I have listed a few ideas for you below in an action plan format:

  1. Verify the organizations expectations and responsibilities are formally and informally communicated to the employees.
    1. Verify this through document reviews, personnel file audits, or an interview or survey of employees themselves.
  2. Review the compliance department/staff are regularly present at meetings and are a visible presence in the organization.
  3. Audit that a compliance representative has attended meetings, including senior management and governance-level meetings.
  4. Survey employees to determine their understanding of material presented at meetings.
    1. Conduct post-training evaluations.

It is very important to make sure that what you think the organization is doing, is really being understood by the staff. Ask yourself the following questions:

-What are the perceptions of the employees?

-How accessible is your compliance department/staff?

-Do your employees know how to report a concern and to whom?

-Lastly, as a company, are you taking the reports seriously by addressing each concern adequately?

If you answered yes to these questions, now go and verify it with your staff and see if your staff correlates with your thinking.

Next week we will touch on Education and Training in compliance. Some of you may have plenty to do with in the week to get caught up and meet all the standards outlined in this document.

Background Information:

On January 17, 2017, a group of compliance professionals and staff from the Department of Health and Human Services, Office of Inspector General (OIG) met to discuss ways to measure the effectiveness of compliance programs. The intent of this exercise was to provide a large number of ideas for measuring the various elements of a compliance program. Measuring compliance program effectiveness is recommended by several authorities. This list will provide measurement options to a wide range of organizations with diverse size, operational complexity, industry sectors, resources, and compliance programs.

The link to the OIG site as to what to measure and how to measure is below. There is a lot of valuable information in this section and I highly recommend you review them.  If you want to review the what and how’s to measure element #4, the link is https://oig.hhs.gov/compliance/101/files/HCCA-OIG-Resource-Guide.pdf .

Should you have any questions or want a consultation of your program, please contact me at karen@bcgdata.net.