Do External Evaluations of Compliance Program Effectiveness Matter?

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By Michael Comeford
michael_comerford@harvardpilgrim.org

The inaugural meeting of the Healthcare Enforcement Compliance Institute has thus far proven a success.  HCCA and its planning committee gathered an extremely knowledgeable and well-rounded group of individuals…government employees, attorneys and compliance professionals alike.  The sessions I’ve participated in Sunday and Monday were very useful and I’ve taken away a great deal of information that I hope I can apply to my organization’s compliance program.

There was one session of particular importance to me – external evaluation of compliance program effectiveness – of particular interest to me given my compliance program has gone through two evaluations thus far (once last year by an external consultant hired by me and once this year by my Internal Audit department).  I’ve heard Steve Ortquist present many times in the past and he’s proven to be an outstanding speaker – this time was no different.

Benton Curtis and Carolyn McNiven did an equally outstanding job.  While my compliance program is required to be evaluated annually by someone outside of the compliance department, my gut tells me that a having someone outside of the organization entirely – a completely new set of eyes – allows for a fresh look at how your program is operating and how it might be enhanced to best position your company for success.  Today’s session confirmed this for me.  Thanks Steve!