years. Last year, I became the Chief of the
Administrative and Civil Remedies Branch.
GI: Can you describe your responsibilities presently at the Office of Counsel to the
Inspector General of HHS?
SG: In my current position, I oversee the
work of 50 attorneys and professional staff
working on OIG-initiated litigation, False
Claims Act (FCA) and self-disclosure cases,
and compliance work. I focus on how OIG’s
penalty and exclusion remedies can best protect the federal healthcare programs and their
beneficiaries. This perspective lets me apply
my experience overseeing CIAs to the decisions we make in all enforcement cases and
compliance monitoring. We thoughtfully leverage our compliance expertise to complement
the work we do in enforcement under the Civil
Monetary Penalties Law and the FCA.
GI: Please explain your role in developing and participating in HCCA’s Office of
Inspector General Roundtable event for measuring compliance program effectiveness and
in publishing the Resource Guide.
SG: In mid-2016, OIG started talking about
how we could gather information from the
industry about whether and how to measure
the effectiveness of compliance programs. We
knew that this was an issue that has been dis-
cussed at length for years in the compliance
world, and we wanted to see if there was a
way we could issue some guidance on it. We
approached HCCA, and they were enthusiastic
and knowledgeable partners in the collabora-
tion. A few of my colleagues and I coordinated
closely with the leadership at HCCA to iden-
tify a broad range of participants who could
give firsthand experience about implement-
ing and measuring compliance efforts on a
day-to-day level in healthcare settings. We
asked them to come prepared with ideas about
compliance successes and how to measure
them. During the event, members of OCIG
acted as facilitators and participated in discus-
sions, but we mostly listened. Any opportunity
for us to hear directly from the compliance
leaders is so valuable.
GI: Tell us about the format for gathering
information and the Roundtable discussion
and how the Resource Guide was created.
SG: During the Roundtable meeting, we
split participants into groups, each group
covering a different topic. The topics were
derived from the seven elements of a successful compliance program: standards,
policies, and procedures; compliance program administration; screening/evaluation
of employees, physicians, vendors, and other
agents; communication, education, and
training on compliance issues; monitoring,
auditing, and internal reporting systems;
discipline for non-compliance; and investigations and remedial measures. We also added a
At the event, participants named ideas for
things to measure and how to measure them.
Scribes took notes on the suggestions. The
groups did not debate the merits of any ideas;
we just wanted to generate as many ideas as
possible. We were able to collect the raw data
from the compliance professionals who use
these tools every day.
We worked with HCCA after the event
to organize and include all the ideas in the
Resource Guide, and the Inspector General,
Dan Levinson, released the Guide during his
speech at the HCCA 2017 Compliance Institute.
GI: Why was this Roundtable event and
preparation of the Resource Guide important
to the Office of Inspector General of HHS?
SG: The opportunity to hold the
Roundtable was exciting for us, because gaining feedback and practical examples from
the compliance community is invaluable and