Billing monitoring: Weakest link or greatest strength?

It is well known from the various compliance program guidance documents issued by the Department of Health and Human Services Office of Inspector General (OIG) that any effective compliance program must contain an internal auditing and monitoring element. Auditing and monitoring should address both the compliance program with its own operations as well as the compliance high-risk areas that impact operational areas.  Auditing and monitoring are crucial elements in establishing and maintaining an effective compliance program as well as a functioning system of internal controls.