1. Establish standards and procedures to prevent and detect criminal conduct.
2. Assign responsibility to oversee compliance with the standards and procedures to specific individual(s) within high-level personnel of the organization.
3. Use reasonable efforts not to include within the substantial authority personnel of the organization any individual whom the organization knew, or should have known through the exercise of due diligence, has engaged in illegal activities or other conduct inconsistent with an effective compliance and ethics program.
4. Communicate periodically and in a practical manner its standards and procedures, and other aspects of the compliance and ethics program, to members of the governing authority, high-level personnel, substantial authority personnel, the organization's employees, and, as appropriate, the organization's agents, by conducting effective training programs and otherwise disseminating information appropriate to such individuals' respective roles and responsibilities.
5. Take reasonable steps to ensure that the organization's compliance and ethics program is followed, including monitoring and auditing to detect criminal conduct; to evaluate periodically the effectivenm of the organization's compliance and ethics program; and to have and publicize a system, which may include mechanisms that allow for anonymity or confidentiality, whereby the organization's employees and agents may report or seek guidance regarding potential or actual criminal conduct without fear of retaliation.
6. Promote and enforce the compliance program consistently throughout the organization through appropriate incentives to perform in accordance with the compliance and ethics program; and appropriate disciplinary measures for engaging in criminal conduct and for failing to take reasonable steps to prevent or detect criminal conduct.
7. After criminal conduct is detected, take reasonable steps to respond appropriately to the criminal conduct and to prevent further similar criminal conduct, including making any necessary modifications to the organization's compliance program.
Instructions
Chapter 18 discusses Corporate Compliance. Our reading addresses several areas of concern but also how to have effective compliance programs in your organization.
Please support your answer using the information from your text for your response. You may also visit the Office of the Inspector General as well to assist in answering:
Compliance Education Materials
Figure 18.5 lists seven steps for an effective compliance program after reviewing this section of your reading and on page 463 for the OIG minimum program elements. Specifically addressing audit trails and data quality monitoring programs.
You have been asked to develop an compliance program for your facility. Please pick 4 of the elements listed on page 463 and discuss in detail and recommend steps to implement that element in your facility for this weeks assignment.
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