Dinsmore health care partner Joseph Zielinski was published in the most recent edition of New Perspectives on Health Care Risk Management, Control and Governance, the publication of the Association of Health Care Internal Auditors. His article, "The Effectiveness of Your Compliance Program," covers how to effectively audit your organization's compliance program while gaining valuable insights. An excerpt is below.

There are three fundamental questions:

• Is the compliance program well designed?
• Is the program being applied earnestly and in good faith? Is it adequately resourced and empowered to function effectively?
• Does the compliance program work in practice?
  
  

With the introduction of the three fundamental questions, the shift towards needing to demonstrate effectiveness (rather than showing that policies and procedures exist) continues. As part of this shift, a greater emphasis is placed on analyzing your program (and failures of your program to use tools such as a root cause analysis) and the use of data and metrics.

Data and metrics are where you need to focus now. Your organization will need to be able to show how data and metrics have informed the compliance program’s priorities and work. Additionally, your compliance program should be designed with the government’s focus on measuring and testing in mind. Finally, if a violation occurred, your organization’s compliance program will need to be able to provide months, if not years, of data to demonstrate the effectiveness of the program.

To apply the three fundamental questions, you must understand what they require.                                                                                                                                                                                                                                                                                      

                                                                                                                                                                                                  Click the download link above to read the full PDF of this article.