Compliance Effectiveness Reviews

Client Situation

One of the largest and most diverse academic medical centers in the country contacted us to review the effectiveness of its corporate compliance program at its two flagship hospitals. At that time, the corporate compliance program had been in place for a little over three years.

Core Competency: Regulatory & Operations Review

Consulting Objectives:

• Conduct an effectiveness assessment to determine if the existing corporate compliance program and all its components will help the client detect noncompliance.
• Review specific elements of the compliance program to assess whether the government would consider them effective in detecting and promptly disclosing potentially fraudulent activities.

Approach:

• Verify the program contains the minimum seven elements as set forth in the Federal Sentencing Guidelines.
• Through a combination of review of strategic documents, administration of surveys and on-site interviews, review the overall effectiveness of the compliance program and adequacy of processes and procedures supporting each of the elements.

Outcomes:

• Detailed recommendations for increasing visibility of the compliance program among the client’s 6500+ employees.
• Identification of deficiencies in employee training and education programs.
• Documentation of current monitoring procedures, recommendations for improvement and development of monitoring systems and procedures by hospital operating area.

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