Monday, February 28, 2005

Auditing yourself
with Clay Stribling
C. Stribling

Q: Does my company need to conduct a self-audit of its compliance program?

A: Self-auditing has many advantages and very few disadvantages. One of the primary advantages, if your company has a corporate compliance program, is to provide evidence that the corporate compliance program is effective. This is very important because an effective corporate compliance program can greatly reduce any fines or penalties that might result from a government investigation. An effective corporate compliance program can also reduce the likelihood that the government will require your company to enter into a corporate integrity agreement as part of a settlement resulting from an investigation.

The following are characteristics of an effective self-audit program:

- An effective internal audit process will become part of what the company does. It will become as much part of the daily, weekly or monthly tasks as filing or working denials.

- An effective audit procedure takes place periodically. The exact period does not matter so much as that an audit happens at defined time intervals.

- Whether the audits are monthly, quarterly, or annually, the audits should address all risk areas for the company.

- Individuals should be held accountable both for the performance of the audits and for implementing any changes that result from the audits.

- Proper documentation of the audit(s) must be maintained.

Clay Stribling is an attorney with the Health Care Group of Brown & Fortunato, P.C., in Amarillo, Texas. Reached him at (806) 345-6346 or