Compliance Program Structure, Governance, and the OIG Seven Elements
The Seven Elements
The OIG's seven elements are the backbone of any healthcare compliance program: (1) written standards of conduct, policies, and procedures; (2) designation of a compliance officer and compliance committee with direct access to the governing body; (3) effective training and education; (4) effective lines of communication, including a hotline and non-retaliation protection; (5) internal monitoring and auditing; (6) well-publicized disciplinary standards and enforcement; and (7) prompt response and corrective action, including investigation and remediation.
What Questions Actually Test
Examiners rarely ask you to recite the list. They test whether you understand that a program must be effective - adequately resourced, empowered with real authority and independence, and actually implemented - not merely adopted on paper. A hotline alone is not "communication"; a policy binder alone is not "written standards." Know that a documented risk assessment drives the whole program, that the governing body must receive regular compliance reporting, and that the compliance officer should not report solely to an executive who owns the audited revenue functions.
Worked Example
A question asks which finding is most serious: (A) no anonymous hotline; (B) the compliance officer reports to the CFO, who also controls billing; (C) training delivered only annually; (D) policies reviewed every two years. The best answer is B - a structural independence defect that undermines oversight, discipline, and response, and therefore the program's credibility with regulators.
Rule of Thumb
Say it, teach it, hear it, check it, fix it - and prove you did all five.