Creating a Culture of Compliance in 2018

Why This Topic Matters

Healthcare organizations face significant regulatory and enforcement exposure, so understanding the broader compliance framework helps leaders evaluate risk, oversight, and internal audit priorities. The article is relevant for anyone responsible for compliance program design, audit planning, or responding to government scrutiny.

Article Sections

1. Healthcare compliance and the need for a risk-based approach

   Introduces the article’s focus on healthcare compliance in hospitals, health systems, and physician practices. It contrasts general compliance efforts with a broader risk-based approach.

2. Federal enforcement guidance and corporate cooperation factors

   Summarizes major Department of Justice guidance referenced in the article and explains the broader role of cooperation, compliance programs, and investigation-related factors. It also identifies the article’s discussion of related DOJ topic areas.

3. Risk-based internal auditing and risk assessment

   Covers the article’s discussion of internal audit design, risk assessment matrices, and policy structure. It also addresses the role of analytics and audit targeting in compliance programs.

4. CMS fraud prevention and audit analytics

   Describes the article’s discussion of CMS fraud prevention technology and predictive analytics. It frames the implications for audit risk and oversight in Medicare fee-for-service environments.

5. Documentation, medical necessity, and compliance program structure

   Focuses on the article’s final compliance themes related to documentation, medical necessity, and overall program structure. It also places these topics in the context of healthcare enforcement and organizational risk.