Kusserow on Compliance: Top initiatives for compliance programs in 2019

In the 2019 survey of health care compliance professionals, compliance professionals were asked about their initiatives for improving their program this year. The responses can be categorized in three tiers. The major focus for respondents was risk identification and mitigation—three of the four highest ranked selections deal with this area. The second tier—earning the third and fifth rankings—involved issues related to HIPAA compliance. The four items at the bottom of the list related to independent assessment compliance program effectiveness: effectiveness evaluation and gap analysis, arrangements with physicians, and compliance knowledge surveys. The third tier included four items, including use of independent parties for gap analysis, effectiveness evaluations, arrangements review, and surveying. The following are the results in descending order:

  1. Working with program managers to improve ongoing monitoring of their risk area (57 percent)
  2. Building a more robust ongoing auditing program (51 percent)
  3. Enterprise-Wide Regulatory Risk Assessment (34 percent)
  4. HIPAA Privacy and Security Assessment (43 percent)
  5. HIPAA Security/Cyber-Security Compliance Evaluation (31 percent)
  6. Independent Compliance Program Effectiveness Evaluation (22 percent)
  7. Independent Compliance Program Gap Analysis (14 percent)
  8. Independent Compliance Review of Arrangements with Physicians (9 percent)
  9. Independently developed/administered Compliance Knowledge Survey (6 percent)

Also noteworthy is the fact that approximately one quarter of those participating in the survey passed on answering this question, either because they have not yet developed a plan, had it approved, or don’t have annual work plans.

For more information regarding results of the Survey, contact Richard Kusserow, CEO, Strategic Management (rkusserow@strategicm.com).


Richard P. Kusserow served as DHHS Inspector General for 11 years. He currently is CEO of Strategic Management Services, LLC (SM), a firm that has assisted more than 3,000 organizations and entities with compliance related matters. The SM sister company, CRC, provides a wide range of compliance tools including sanction-screening.

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Copyright © 2019 Strategic Management Services, LLC. Published with permission.