DOJ vs. Compliance Programs [Healthcare Compliance Tips]

Compare the DOJ’s compliance document to your compliance program and adjust.

The final resource I would like to share from the series, The Comeback Story: 9 Compliance Resources to Level Up Your Practice is:

DOJ – Evaluation of Corporate Compliance Programs

Purpose:

Created by the U.S. Department of Justice (DOJ) to give prosecutors specific factors to consider during the investigation of a corporate entity. This document helps in the decision-making process to determine whether to bring charges, negotiate pleas, or deal with other agreements.

How to Use It:

Even though the title is labeled “corporate”, this evaluation does not exclude your practice if the DOJ decides to knock on your door. The same guidelines applied in this document apply to you. Therefore, taking the time to get into the government’s head by reading this document is well worth it.

This evaluation provides topics and sample questions that are asked while they review a corporate compliance program. Some of the questions may be relevant and some may not, but this evaluation is still very helpful in the long run.

The 11 topics it covers are as follows:

• Analysis and Remediation of Underlying Misconduct
• Senior and Middle Management
• Autonomy and Resources
• Policies and Procedures
• Risk Assessment
• Training and Communications
• Confidential Reporting and Investigation
• Incentives and Disciplinary Measures
• Continuous Improvement, Periodic Testing, and Review
• Third Party Management
• Mergers and Acquisitions

Series Conclusion

The compliance process is tedious to say the least. Even the government knows this.

And, just like my mental block surrounding math didn’t begin overnight, neither do compliance woes.

The good news is the government understands that it is impossible to build a great compliance program overnight. But, they do expect you to study the resources, and then tailor the program to your specialty.

Consider taking a note out of my old professor’s handbook and remove the “calculators” hindering your practice from going from good to great!  It’s time to rewrite your practice story, because if you don’t, the news media will.

Besides, everyone loves a comeback story.

**The opinions and observations from the group/author are not a promise to exempt your practice from fines and penalties.  Research, modify and tailor the advice to fit your specialty.