By now, every provider should have the infrastructure of a compliance program in place. The seven elements of an effective compliance program are well publicized and there are numerous resources available to providers for building a program. But, building a compliance program, putting policies and procedures in place, naming a compliance officer and having a hotline, is only half the battle. A compliance program is only valuable if it works to detect and deter bad activity, which begs the question: “how do I know my compliance program is working?”
The absolute best way to determine if the organization’s compliance program truly is effective is to conduct an evaluation of the program looking not just at the infrastructure, but also at how the program weaves into the culture of the organization on a daily basis. While a program evaluation can be done internally, there is a strong tendency for confirmation bias to come into play when an organization is looking at itself. For a more objective evaluation, it is recommended that the evaluation be conducted by an outside set of eyes, so to speak, who is familiar with the industry and the compliance requirements the organization must meet. A valid evaluation will entail a review of policies, procedures, and related documents, as well as personal interviews of the people who carry out the business of the organization on a daily basis in order to determine how things are really done on the front line.
Having an outside party conduct a compliance program evaluation can provide a clear path for improvement, and peace of mind that should something go bump in the night, the compliance program will be there to catch it.