How to Structure Your Compliance Program

Nursing, assisted living, and post-acute facilities have long been an area of scrutiny by the Office on Inspector General (OIG) as they are high-risk areas. It is important that an organization have a formal compliance program as proactive and preventive; a structure to address issues; and as a mitigating factor should compliance violations be identified by regulatory agencies.

OIG recognizes a common structure for compliance programs centered around seven elements. They are:

  • Written policies, procedures, and standards of conduct
  1. How accessible are they to all employees?
  2. How often are they reviewed?
  3. What is the process/procedure for review and approval?
  4. Are they written in understandable language?

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