Healthcare Compliance Program Effectiveness

Healthcare organizations and their ethics and compliance officers have a detailed new resource available to them. The U.S. Department of Health and Human Services, Office of Inspector General (HHS-OIG) recently published Measuring Compliance Program Effectiveness: A Resource Guide, which is intended to provide organizations with detailed metrics for measuring compliance program elements.

HHS-OIG staff met in January 2017 with a group of compliance professionals to discuss ways to measure the various elements of a compliance program. Specifically, participants broke into groups to discuss ideas about “what to measure” and “how to measure” all seven elements of a compliance program, as identified by the Health Care Compliance Association (HHS-OIG, 2017). Those elements are listed below (bolded headings).

Each of those elements is broken down into many measurable sub-categories (“what to measure”), each of those with accompanying suggestions on “how to measure.” The Guide makes it clear that the lists (presented in easy-to-read tables) are intended to provide healthcare organizations with as many ideas as possible, to be broad enough to help any type of organization, and to let organizations choose which ones best suit their needs.

“This is not a ‘checklist’ to be applied wholesale to assess a compliance program,” according to the report. Speaking of the listed suggestions, it states “using them all or even a large number of these is impractical and not recommended.” With good reason—there are 401 suggested metrics in all, grouped as follows:

Standards, policies, and procedures

  • Access
  • Accountability
  • Review/approval process
  • Quality
  • Assessment
  • Code of conduct
  • Updates
  • Understanding
  • Compliance plan
  • Confidentiality statements
  • Enforcement

Compliance program administration

  • Board of directors
  • Compliance budget
  • Compliance committees
  • Accountability
  • Compliance officer
  • Staffing
  • Compliance plan
  • Culture
  • Incentives
  • Performance evaluation
  • Risk assessments
  • Compliance work plan
  • Legal counsel’s role
  • Other (job descriptions)

Screening and evaluation of employees, physicians, vendors, and other agents

  • Accountability for screening
  • Conflict of interest
  • Employee accountability
  • Employee disclosure
  • Employee screening
  • Exit interviews
  • High risk screening
  • Licensure
  • Response to exclusion
  • Response to screening
  • Vendor
  • Vendor screening

Communication, education, and training on compliance issues

  • Training
  • Accountability
  • Awareness
  • Board
  • Communication
  • Competency
  • Culture
  • Incentives
  • Vendors and volunteers

Monitoring, auditing, and internal reporting systems

  • Reporting system
  • Risk assessments
  • Monitoring and auditing work plan
  • Audit process
  • Corrective action plans
  • Auditors
  • Non-retaliation
  • Vendor oversight

Discipline for non‐compliance

  • Consistency
  • Awareness
  • Documentation
  • Promotion criteria

Investigations and remedial measures

  • Guidelines for conducting an investigation
  • Content of investigation files
  • Quality and consistency of investigations
  • Tracking and trending investigations
  • Escalation of investigations
  • Communication of investigation outcomes
  • Training of investigators
  • Professionalism and competency of investigators
  • Independence of investigators
  • Involvement of legal counsel
  • Timeliness of response
  • Corrective action plans/remedial measures
  • Root cause analysis
  • Adherence to non-retaliation policy
  • Government inquiries/investigations
  • Monitoring results
  • Awareness of investigation process
  • Contract provisions regarding investigations

Each of these sub-categories contains a list of suggested, related metrics—a total of 401 metrics overall. And each of those metrics is accompanied by a list of suggested ways to measure them—making this guide a very practical aid for healthcare ethics and compliance professionals. In fact, most of the metrics and implementation suggestions are industry-neutral, making this a powerful addition to everyone’s reading list!

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U.S. Department of Health and Human Services, Office of Inspector General. Measuring Compliance Program Effectiveness: A Resource Guide, March 27, 2017.