From HCCA: A Compliance and Ethics Newsletter

Every organization, its programs, and workforce have standards to meet.

There are also standards for compliance and ethics programs. If those standards are met, it can make a tremendous difference.

The standards established for the structure of an effective compliance program are outlined in The 2011 Federal Sentencing Guidelines (FSG) Manual, Chapter Eight for Effective Compliance and Ethics Programs.

• Governance and High-Level Oversight refers to the board of directors receiving reports about compliance program activities.  The directors must demonstrate knowledge and oversight of the program.
• Establish Standards to maintaining and publishing policies, procedures and a code of conduct that address the risks in business and expectations of the workforce.
• Create a Fair and Ethical Culture to establishing incentives tied to performance for the workforce – “doing the right thing”.
• Open Lines of Communications establishing a confidential reporting for misconduct and surveying the workforce for feedback.
• Education and Training to cover regulatory requirements, training programs and areas of risk.
• Detection, Remediation and Enforcement from screening employees (background checks), establishing sanctions for non-compliance with organizational standards and the law, to ultimately making corrective actions to prevent recurrence.
• Risk Analysis conducted that will find and evaluate operational and organizational risks and taking steps to minimize those risks.
• Auditing and Monitoring refers to ongoing testing of the controls established to minimize risks and ensure controls are working.
• Assessment of Effectiveness to evaluate the compliance program elements and how well they are being met.