Compliance Programs, Audits & Corrective Actions

An effective compliance program is a specific structure — written standards, a compliance officer, training, reporting lines, auditing, enforcement and response — not a binder. We build that structure, test it with internal audits, and write corrective action plans that satisfy the entity that raised the finding.

What is included

• Compliance program design built on the OIG’s seven elements of an effective program
• Compliance officer and committee structure, charter and reporting lines
• Documentation and coding audits, including chart review against medical necessity and documentation standards
• Mock audits modelled on the payer or contractor review you are actually facing
• Exclusion screening processes for the OIG LEIE and state exclusion lists
• Corrective action plan drafting and implementation support
• Response support for payer audits, additional documentation requests and payment suspensions
• Annual compliance training content for staff and leadership

How the engagement runs

1. Risk assessment — where your provider type, service mix and documentation habits create the most exposure.
2. Baseline audit — a sample of records reviewed against the standards that would be applied in an external review.
3. Program build or repair — the structural elements, written and operational rather than nominal.
4. Corrective action — findings converted into a plan with owners, dates and evidence of completion.
5. Re-audit — the same review repeated to demonstrate the correction held.

Who this is for

Organizations receiving audit letters or additional documentation requests, providers under a corrective action plan, groups whose compliance program exists on paper only, and any organization that wants to find its own problems before someone else does.

Frequently asked questions

What are the seven elements of an effective compliance program?

Written policies and standards; a designated compliance officer and committee; effective training and education; effective lines of communication including a reporting mechanism; internal monitoring and auditing; enforced standards through well-publicised disciplinary guidelines; and prompt response to detected offences with corrective action. The framework comes from HHS Office of Inspector General compliance guidance.

We already got an audit letter. Is it too late to call you?

No, and this is one of the most common ways clients arrive. What matters is the response deadline in the letter. Send us the letter and the deadline first — the response window drives everything else.

Does an internal audit create discoverable evidence against us?

This is a real question and it is a legal one. How an audit is structured, who directs it, and whether it is conducted under privilege are decisions to make with counsel before the audit starts. We routinely work alongside healthcare counsel for exactly this reason.

Related

• Policies & Procedures
• Survey & Accreditation Readiness