Effective Monitoring and Auditing Programs
Dan Roach, General Counsel, Optum360
April 20, 2015
I attended another great session by former Dignity Health General Counsel Dan Roach. Dan was one of MD Ranger's first champions and helped us implement MD Ranger across Dignity Health five years ago.
Auditing and monitoring programs protect organizations by identifying issues early and demonstrate a commitment to compliance program effectiveness. In fact, federal sentencing guidelines say you do not have an effective compliance programs unless you have these programs in place! Keep in mind that these programs serve to protect the compliance officer, if you need yet another reason to implement one at your organization.
Dan hammered home that incentives must align across the organization for behaviors to change and for a culture of compliance to thrive. He also recommends being as transparent as possible with monitoring and auditing programs.
Common pushback from organizations usually revolves around resources. Many organizations don't have large compliance teams, and the staff already have a full workload. After all, if problems are identified, they must be corrected. This takes even more time and resources.
Dan also discussed the differences between auditing and monitoring. Auditing is a sample, periodic, retrospective analysis of a system. Monitoring, on the other hand, is a continuous, frequently automated process that looks at what's happening now.
What happens when mistakes are uncovered in your monitoring/auditing programs? Take action! Corrective action plans help an organization take a reasonable approach. Dan suggests automating where it is possible. However: beware of the ineffective plan. Just because a corrective action plan is in place doesn't necessarily mean that your organization will successfully correct what's been going wrong.
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