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10 Indicators Your Compliance Program is Effective
April 2014
David Rosenthal: VP, Marketing & Strategy, HCCS
David Rosenthal, VP

You’ve spent countless hours establishing a high quality effective compliance program within your facility and want to see the result of that effort.  However, compliance is difficult to measure.  What are some of the signs that indicate that your compliance program is reducing risk?

  1. Calls to hotline increase – While it might seem counter-intuitive that a better compliance program leads to more hotline calls, it really is not.  Would you rather know about a potential problem now and have an opportunity to fix it, or wait and be surprised by a CMS audit or whistleblower action that could lead to even larger problems for your organization?  As the understanding and issues of compliance spread throughout your organization, many questions and observations will come up.  Not all of them will be true compliance issues but increased queries show an enhanced level of engagement by your staff with compliance.  

  2. Staff members stop you in the hallway to ask compliance questions – As the understanding of compliance grows within your facility, it’s natural that staff will have questions and want further guidance.  

  3. Compliance shows up on agendas of non-compliance meetings – You’ll know that compliance is being taken seriously in your organization when it’s regularly discussed without the participation of the compliance officer.  This will indicate that compliance is ingrained into the fabric of the organization.

  4. You are asked by individuals and departments to come in to review compliance related issues such as documentation or billing – All of those meetings lead to action items that require the resources of the compliance officer.  It’s good to be needed!

  5. Staff talk about the compliance training – Training will always elicit some complaints and those learners are usually the most vociferous.  However, when you have an effective compliance program backed up by high quality training courses, you should hear an occasional positive comment about something that was interesting in the course.  

  6. Documentation improves – Just ask your coding staff!

  7. The CEO, Executive Team and Board of Directors ask you to discuss compliance procedures in your organization – Now you know you’ve got their attention when it reaches the highest levels of the organization.  An engaged BOD signals an awareness of the importance of compliance and leads to further compliance effectiveness.

  8. You aren’t chasing as many people to complete their compliance training requirements – Staff are more willing to complete training when they understand the need for it and it is presented in a high quality format that provides relevant job-specific content.  This frees up your limited compliance office resources to focus on high-risk activity.

  9. Staff no longer run away when they see you coming – Do you sometimes feel like you have a contagious disease?  Do staff members avoid you when you come into their department?  The role of compliance officer should not be adversarial.  An effective program puts everyone on the same team, pulling together.  The first sign of a good compliance program is that staff members can easily identify the compliance officer and no longer hide when they see you walking down the hallway.

  10. Internal audits are showing fewer issues – All that work has paid off.  This requires annual attention to the compliance program and effective training.

How does your compliance program measure up against these indicators?

Did you like this article? Have comments, ideas, suggestions? Please email me at

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