The Department of Justice (DOJ) has issued guidance regarding common questions and issues that are pertinent in evaluating the effectiveness of a corporate compliance program.  The 8 page document covers a number of topics and emphasizes the need for an active compliance program designed to effectively detect, investigate and respond to compliance concerns with active participation and commitment at the senior management level.  The guidance also addresses the experience and qualifications of personnel in compliance positions, the effectiveness of current policies and procedures and training, and the frequency and effectiveness of education and training.

The categories addressed in the guidance include:

1. Analysis and Remediation of Underlying Misconduct
2. Senior and Middle Management
3. Autonomy and Resources
4. Policies and Procedures
5. Operational Integration
6. Risk Assessment
7. Training and Communications
8. Confidential Reporting and Investigation
9. Incentives and Disciplinary Measures
10. Continuous Improvement, Periodic Testing and Review
11. Third Party Management
12. Mergers and Acquisitions

The entire guidance can be located at: https://www.justice.gov/criminal-fraud/page/file/937501/download

We have a team of compliance experts that includes certified coders as well as individuals Certified in Healthcare Compliance who routinely provide assistance with the key compliance program elements outlined by the Department of Justice.  Our services include auditing and monitoring of documentation, coding and claims, risk assessments, internal investigations, development of corrective action plans and policies and procedures, as well as preparation of customized education and training.

If you would like assistance with your compliance program needs, please contact us.