Tips on Developing Compliance Policies and Procedures
The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) has issued a number of compliance program guidance documents, all of which stress, in turn, the importance of written compliance guidance for employees. The OIG notes that, “At a minimum, comprehensive compliance programs should include … the development and distribution of written standards of conduct, as well as written policies and procedures that promote the [organization’s] commitment to compliance and that address specific areas of potential fraud, such as claims development and submission processes, code gaming, and financial relationships with physicians and other health care professionals.” 1 The United States Sentencing Commission Federal Sentencing Guidelines notes that to “have an effective compliance and ethics program.., an organization shall … establish standards and procedures to prevent and detect criminal conduct.”
