Annual Compliance Program Audit: Your Organization’s Achilles Heel?

January 8, 2015
|In Compliance, Brain Food
|By GHG Advisors

When it comes to auditing throughout the Organization, the truth is that much of the responsibility often falls directly on the Compliance Department. This can be due to many factors, such as lack of resources or lack of cross-functional expertise. However, one of the CMS Compliance Program requirements is that the Compliance Program itself is audited annually. Fulfilling the requirement to annually audit the Compliance Program can present an issue for some Organizations due to the fact that Compliance Department self-auditing does not fulfill the requirement, and there may be no other department within the Organization with the expertise to conduct the review.

Here are a few ideas that we’ve seen Organizations use in order to fulfill the CMS requirement:

  1. Hire an external auditing firm.
  2. Cross-train another department within the Organization to conduct the annual audit.
  3. Compliance departments of two different Organizations audit each other. Of course, this option may be a bit tricky depending on the competitive landscape. However, it can be a good option if there is no budget to hire an external firm and if no conflict exists (e.g. competing service areas).

An effective Compliance Program is critical to your compliance and operational success. In addition, a strong Compliance Program can safeguard against many compliance issues recently cited by CMS as the cause for civil monetary penalties (CMPs) and enrollment sanctions. Please contact us for more information about the GHG Compliance Program Effectiveness Audit.

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