Compliance Program AssessmentIndependent and Objective Consultation with a Proven Track Record
One of the seven elements of an “effective compliance program” as defined by the Federal Sentencing Commission more than a decade ago, is a periodic critical review of the program to ensure it meets its objectives and accurately reflects the organization’s operations and compliance risks. Our comprehensive assessment process is designed to conduct such a compliance program review, and provide practical advice on how a client’s compliance program can better address the business and management needs of the organization.
With the increased focus on corporate governance and board oversight of management practices, the compliance program can play an important role in ensuring that an organization’s corporate governance structure is effective. Our assessment report gives the compliance officer, the board of directors and executive management guidance on how the organization’s compliance program can be fortified to ensure that it meets its objectives.
The Program Assessment process consists of a desk review of organization policies, procedures and compliance-related reports. In addition, on-site interviews are conducted throughout the organization to obtain a representative sample of employee perception of the effectiveness of the program and the compliance staff. We interview both management and line employees in order to determine strengths and weaknesses of the existing compliance efforts.
“The Compliance Program Assessment is an extremely valuable tool for Compliance Officers and Boards of Directors. There is a major impact to having an external evaluation and validation of the functioning of a Compliance Program, both with regulators/payers and significantly, within the organization itself. Most expecially useful to the Compliance Officer are the recommendations for improving even strong programs, making them stronger still. The CRG staff are experienced and easy to work with.”
Below are some of the elements and baseline measures we evaluate when conducting program assessments:
“Oversight and Support”
- Governance structure of the organization and the program.
- Management support of the compliance efforts.
“Corporate Compliance Office and Officer”
- Compliance function status within the corporate organization.
- Structure and resources of compliance office.
- Delegated compliance responsibilities.
“Code of Conduct and Policies”
- Content and effectiveness of Code of Conduct.
- Distribution of Code and employee awareness.
- Review of corporate policies and procedures.
- Review of compliance-related policies and procedures.
“Internal Reporting Process”
- “Hotline” and other formal reporting mechanisms.
- Informal reporting processes.
- Effectiveness of review process and procedures.