In addition to monitoring your operations and auditing the organization’s performance, CMS also audits the compliance function. In recent years many CMS sanctions have been issued as the result of a Compliance Program that was determined to be ineffective.
During CMS audits conducted of the Compliance Program, CMS found that many organizations were not conducting annual risk assessments, and therefore had not implemented effective monitoring and auditing plans. CMS also found that corrective action plans were not documented or implemented within a reasonable timeframe. Delegation oversight? Don’t ask. Can everyone in the organization state what the seven compliance program elements are, and who is the compliance officer? And when did they receive their last compliance training?
While it may be difficult (too much so, for our tastes) for many compliance officers to effectuate the necessary change in the business units, it is not impossible. Let us help you create a culture of compliance.
Help your organization learn the elements of a Compliance Program.