The U.S. Department of Health and Human Services OIG has identified these seven fundamental elements of an effective compliance program:
- Written Policies and Procedures
- Compliance Leadership and Oversight
- Training and Education
- Effective Lines of Communication with the Compliance Officer and Disclosure Program
- Enforcing Standards: Consequences and Incentives
- Risk Assessment, Auditing, and Monitoring
- Responding to Detected Offenses and Developing Corrective Actions Initiatives
An example of a Voluntary Compliance Program based on these seven fundamental elements follows on the next several pages.
