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Element 5: Monitoring, Auditing, and Internal Reporting Systems


Below, is the list that was outlined on January 17, 2017 of what the OIG and team believed was important in the monitoring, auditing and internal reporting systems of element #5 in any organization.

Element 5: Monitoring, Auditing, and Internal Reporting Systems

  1. Protect anonymity and confidentiality within legal and practical limits.
  2. Publicize the reporting system to all workforce members, vendors, and agents.
  3. Assure monitoring occurs for violations of laws and regulations.
  4. Conduct organizational risk assessments.
  5. Develop work plan based on risk assessment.
  6. Maintain reporting system(s) to enable employees to report any noncompliance (e.g., hotline).
  7. Respond to compliance concerns expressed by employees through internal reporting.
  8. Assure the existence of procedures for monitoring adherence to compliance policies and procedures.
  9. Conduct compliance audits.
  10. Analyze compliance audit results (e.g., track, trend, benchmark).
  11. Develop an annual compliance audit plan.
  12. Evaluate results of audits conducted by external entities.
  13. Monitor that retaliation for reporting compliance concerns has not occurred.
  14. Recognize need for attorney consultation in the auditing/monitoring process.
  15. Employ auditing methodologies that are objective and independent.
  16. Determine sampling methodology consistent with circumstances.
  17. Assure a timely response is made to reported compliance concern

Let’s take a deeper look at this and what the OIG is expecting of companies in measuring the audit program.

Measuring You’re Monitoring, Auditing and Internal Reporting System:

The report has many suggestions on how to measure these points, and I have listed a few ideas for you below in an action plan format. For more ideas, please go to the website highlighted at the end of this blog.

  1. Conduct interviews of staff
  2. Provide surveys to staff
  3. Adhere to the 60-day overpayment rule
  4. Review documentation of the hotline system
  5. Track hotline call issues to find common denominators
  6. Audit dates of hotline calls, when reviewed, investigated, and closed
  7. Monitor to ensure disciplinary issues are followed and consistent
  8. Develop a fraud assessment plan and follow the plan
  9. Is the risk assessment implemented and monitored?
  10. Review risk assessment process
  11. Provide documentation of who is authorized to initiate and audit
  12. Create audit reports for compliance audits that identify purpose, scope, objectives, and resources
  13. Ensure all vendor contracts include consistent compliance language
  14. Review vendor certifications
  15. Perform exit interviews
  16. Review employee surveys
  17. Audit and review for consistency throughout organization
  18. Validate all audit results

Questions to Ask:

Here are some questions to ask of yourself and staff about your organizations operations concerning element #5.

Is the reporting system accessible to employees? Is it available to everyone in the staff’s native language?  Are calls being received through the hotline monitoring system?  Are investigations being followed up and documented from start to resolution?  Are hotline posters posted in open common areas? Does your staff know who to report concerns to? Are your audits and monitoring based upon identified risk areas in the risk assessment?  What is your gift policy and is it being followed by staff?  How are audit results reviewed and resolved?

If you answer “no” to any of these questions, it might be a great time to review your audits and monitoring policy and make changes where necessary. It is important to verify your answers with the facts and documentation of the organization.  It is very important to make sure that what you think the organization is doing is really being performed by the staff.

If you are in need of a hotline system, please contact BCG Research and we can get you set up!

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.  For more detailed information or if you want to review the what and how’s to measure element #5, the link is https://oig.hhs.gov/compliance/101/files/HCCA-OIG-Resource-Guide.pdf

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.

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