help improve our guidance and CIAs. As a
government agency, our goal is to protect
the federal healthcare programs in a myriad
of ways. One way we do that is by distributing guidance to the industry for providers
who are trying to follow the laws and be
compliant. Another way that we do that is by
entering into CIAs and posting them to our
website. Our goal for this Roundtable was
to be able to provide resources to industry
related to measuring compliance success, as
well as to hear ideas from industry that could
make our guidance and CIAs more effective.
We knew we would get the best ideas from
industry telling us directly how compliance
officers have started measuring the value
of the work done by their departments. We
think the Resource Guide does a great job
of providing valuable ideas to compliance
professionals, without setting a standard or
endorsing any checklist of activities.
GI: What do you think compliance professionals learned from the Roundtable event?
What do you think the Office of Inspector
General learned from the Roundtable event?
SG: I think everyone at the event gained a
better understanding of the breadth of ideas
that compliance professionals have been
implementing over the past number of years.
The sheer volume of ideas, as evidenced by
the length of the Resource Guide, told us at
OIG how hard the healthcare compliance
world has been working to check its effectiveness. The compliance community is very
engaged in this process.
GI: What are some ways that the Office
of Inspector General and compliance professionals can use the Resource Guide?
SG: There are many ways compliance
professionals can use the Guide. Some have
already reported back to us that they have
incorporated metrics from the Guide into
their programs. Its use will depend in part
on the level of resources in any given compli-
ance program. As we stated in the Guide, it
is not meant to be a checklist; using all the
suggestions there would be overwhelming
and likely overbroad for most providers.
For example, a small healthcare provider’s
compliance program may find a compliance
element they have been focused on recently
in the Guide and take one or two ideas to test
how those efforts have been working. Larger
programs may test ideas in multiple elements
in any given year. As for OIG, we are using
the Guide to gain a window into compliance
efforts in the real world. We are very much
hoping that compliance officers will report
back to OIG and HCCA about how they are
incorporating the ideas. We would be open to
improving the Guide to make it as useful as
possible in the future. OIG is always open to
ideas from industry stakeholders about how
to strengthen compliance programs.
GI: The Office of Inspector General has
been an increasing presence and leader in
promoting organizational compliance. What
are some of the things you can point to in
recent years that have been important in this
SG: We have been working very hard to
promote compliance in specific ways and be
transparent to the healthcare community.
In 2016, we released our updated criteria for
implementing permissive exclusion authority
under section 1128(b)( 7) of the Social Security
Act. This guidance explains to the community how OIG makes enforcement decisions,
from when we will provide a release without a CIA to when we might exclude. We
hope it is used by compliance programs to
encourage self-disclosure and set expectations for when OIG will consider an entity to
be high risk. It, combined with our revised
Self-Disclosure Protocol, released in 2013, can