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Using the OIG model compliance programs to fight fraud.

Many healthcare organizations already have implemented compliance programs for their facilities. However, in light of recent fines and continued scrutiny of such programs by the HHS Office of Inspector General (OIG), healthcare organizations should consider reviewing their current programs against the OIG's relevant model compliance program. Although healthcare organizations are not required to adhere strictly to OIG's model programs, they would benefit from ensuring that their programs meet all the OIG's requirements. The common, minimum elements suggested by the OIG model programs include development and distribution of written compliance policies, the designation of a chief compliance officer to manage the program, the development of a corrective action and enforcement system, and the use of audits to monitor compliance. Using these models as guides, healthcare organizations should be better able to avoid the possibility of fraud and abuse within their organizations.