Healthcare organizations, senior executives, and governing body members are under increasing scrutiny to ensure they have an effective compliance program. In 2023, the Department of Justice (DOJ) again updated its compliance program guidance. This guidance provides insight into how the DOJ evaluates the effectiveness of a compliance program when conducting investigations. Many healthcare organizations utilize a third-party to perform periodic compliance program effectiveness reviews (as set out in the Federal Sentencing Guidelines). Those under Corporate Integrity Agreements (CIAs) are often required to hire a compliance expert to perform such a review under the Board of Director’s obligations under the CIA and as part of its annual report.
Coker’s compliance team will perform a comprehensive evaluation of your organization’s existing compliance program against the seven fundamental elements, OIG compliance guidance, and DOJ guidance, and offer recommendations to improve the effectiveness of your program. Coker’s approach involves employee surveys and a deep dive tracing of matters within your existing program to assure the program is operating as intended. Coker has the tools and resources to assist you in implementing improvements in your program and is available for ongoing execution, support, and advisory services.