Corporate Responsibility Audit Work Program

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Structured Corporate Integrity and Compliance Program Evaluation

This Corporate Responsibility Audit Work Program provides a detailed framework for conducting audits of a company’s corporate responsibility program (CRP), ensuring compliance with established benchmarks and regulatory requirements. It outlines the audit objectives, which include evaluating the effectiveness of the CRP, measuring adherence to compliance standards, and ensuring the implementation of the seven elements of an effective compliance program. The scope encompasses inquiries with the corporate responsibility officer (CRO); reviews of meeting minutes, policies and procedures; assessments of educational activities; and evaluations of environmental risk management processes. Additionally, it includes steps to examine excluded provider screening processes and ensure compliance with corporate integrity agreements or settlement agreements.

This document includes two samples, each addressing different aspects of the audit process. Sample 1 focuses on high-level oversight, including the structure of the CRP, committee reporting and documentation of compliance-related issues. Sample 2 delves into more detailed auditing steps, such as monitoring employee training, investigating hotline reports, and reviewing claims and coding audits. It also emphasizes corrective action plans, vendor and physician screening and quarterly investigation summaries. Together, these samples provide a robust methodology for ensuring that the company's CRP is effective, transparent and aligned with best practices.

Audit work steps include:

  • Obtain a copy of the agenda for the most recent associate orientation.
  • Document the percentage of employees that have received some type of annual CRP training.
  • Document the process to make certain all associates attend orientation within 90 days of commencing employment.
  • Document the process to investigate hotline calls.