Tips for Conducting a Mid-Year Compliance Review

The U.S. Health and Human Services Office of Inspector General (OIG) said it best: “An ongoing evaluation process is critical to a successful compliance program.”  With 2023 halfway over, it’s a great time to pause and reflect on your compliance program’s wins and areas of opportunity for the remainder of the year.

Here are three ways to evaluate your compliance efforts and identify new avenues to focus on in 2023.

#1. Conduct Risk Assessments

Most compliance professionals know that they should conduct annual risk assessments to proactively identify and address the broad spectrum of complex and ever-evolving compliance risks.

But annual assessments aren’t enough – organizations need to continually review their programs and adjust accordingly to keep up with the changing healthcare landscape.

• • When was your organization’s last risk assessment?
  • How have you incorporated the findings from that assessment into your current program?
  • What new risks and areas of focus do you need to integrate into your compliance efforts?

Looking for more? Check out our Risk Assessment Design resource.

#2. Stay Informed on Department of Justice Updates

Enforcement actions and updates from the DOJ are a critical way to fine tune your programs and stay in the know about potential areas of risk.

These questions come straight from the DOJ:

• • How often has the company updated its risk assessments and reviewed its compliance policies, procedures, and practices?
  • Has the company undertaken a gap analysis to determine if particular areas of risk are not sufficiently addressed in its policies, controls, or training?
  • What steps has the company taken to determine whether policies/procedures/practices make sense for particular business segments/subsidiaries?
  • Does the company review and adapt its compliance program based upon lessons learned from its own misconduct and/or that of other companies facing similar risks?

#3. Keep Up With OIG Compliance Guidance

The OIG is constantly updating their Work Plan to include new focus areas and concerns, so compliance professionals should keep up with those ongoing changes to ensure their programs address new risks.

Below you’ll find some questions included in OIG guidance:

• • Has the hospital developed a risk assessment tool, which is re-evaluated on a regular basis, to assess and identify weaknesses and risks in operations?
  • Is the audit plan re-evaluated annually, and does it address the proper areas of concern, considering, for example, findings from previous years’ audits, risk areas identified as part of the annual risk assessment, and high-volume services?

Resources for Compliance Professionals

We know that keeping track of all these changes and updates is a monumental task, which is why we provide ongoing compliance and auditing content designed to keep you informed about the latest from the DOJ and OIG.

Pop over to our Resource Center and browse our latest eBriefs, webinars, and checklists.

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