Regulatory compliance and corporate compliance are different disciplines that get conflated. Passing a survey says nothing about your exposure under the False Claims Act, the Anti-Kickback Statute or Stark Law.
The seven elements
OIG compliance program guidance is organized around seven elements, and an effective program has to demonstrate all of them, not just a binder for the first one:
- Written policies, procedures and a standards-of-conduct document people have actually read
- A compliance officer and committee with genuine authority and a reporting line that does not run through the people they may need to investigate
- Effective training and education, targeted by role
- Open lines of communication, including a reporting mechanism people trust enough to use
- Auditing and monitoring driven by risk, with documented follow-up
- Consistently enforced standards and disciplinary guidelines
- Prompt response to detected offences, including the disclosure decision
Practical areas we work in
- Exclusion screening against the OIG LEIE and state lists, at hire and monthly thereafter, covering contractors and vendors as well as employees
- Documentation and coding audits — medical necessity, level-of-service support, incident-to and supervision requirements
- Physician financial arrangements reviewed against Stark and Anti-Kickback exceptions and safe harbours, with fair market value documented
- Overpayment identification and the 60-day repayment obligation
- Board reporting that demonstrates real oversight rather than an annual acknowledgement
We are consultants, not attorneys, and we do not provide legal advice. Where a matter carries legal exposure we work alongside your counsel — often at their direction, so the work stays privileged.