Timely and impartial compliance assessments are vital for healthcare organizations aiming to uphold regulatory standards and foster a culture of integrity. Conducting these evaluations early in the fiscal or calendar year ensures that organizations can proactively identify and address potential issues, integrate findings into their annual planning, and demonstrate leadership’s commitment to compliance. External experts bring an unbiased perspective, providing valuable insights into how effectively a healthcare entity’s compliance program is designed, implemented, and maintained. Both the Department of Health and Human Services (HHS) Office of Inspector General (OIG) and the Department of Justice (DOJ) emphasize the importance of periodic independent reviews, considering them a best practice for ensuring ongoing adherence to legal and ethical standards.
The OIG, in particular, recommends routine independent assessments as a crucial element of compliance management. During investigations or settlement negotiations, authorities often scrutinize whether organizations have engaged external evaluators to review their compliance programs. These evaluations serve as objective evidence that a healthcare organization is actively monitoring and improving its compliance efforts, which can be advantageous in legal or regulatory reviews.
It is widely recognized that effective compliance must be a top-down initiative, starting with the governing board. Boards are expected to take an active role in overseeing the integrity of compliance programs through regular, independent assessments. By commissioning these evaluations and thoroughly reviewing the results, board members fulfill their fiduciary responsibilities and demonstrate their commitment to organizational accountability.
Over the past three decades, Strategic Management Services has conducted hundreds of these assessments, consistently finding that scheduling them early in the year—whether aligned with the calendar or fiscal year—maximizes their benefit. Early evaluations allow organizations to incorporate findings into their annual compliance work plans and risk assessments, ensuring that resources are allocated to remediate deficiencies promptly.
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Furthermore, early-year assessments provide leadership with timely insights, enabling compliance committees and executives to set priorities with an accurate understanding of current risks. They also help determine whether additional resources, such as staff training, monitoring tools, or corrective measures, are needed to meet regulatory expectations within the same fiscal cycle. Conducting assessments early demonstrates that compliance is an ongoing priority rather than a reactive measure, reinforcing a proactive culture of continuous improvement.
Receiving evaluation results at the start of the year allows compliance officers and leadership to track progress, address vulnerabilities, and seize opportunities for enhancement. This proactive approach not only supports regulatory adherence but also promotes operational excellence. For organizations seeking guidance on strengthening their compliance initiatives, engaging with experienced professionals can be invaluable. To explore how our compliance experts can assist, contact us to arrange a consultation.
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About the Author
Richard P. Kusserow founded Strategic Management Services, LLC, after serving as the DHHS Inspector General. With extensive experience, he has supported over 3,000 healthcare organizations in developing, implementing, and evaluating compliance programs to ensure regulatory adherence and operational integrity.