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Lessons Learned: Ongoing Monitoring vs. Ongoing Auditing

What’s the difference between monitoring and auditing a healthcare compliance program?

What's the difference between monitoring and auditing a healthcare compliance program?The Office of Inspector General (OIG) at the U.S. Department of Health and Human Services (DHHS), in their various compliance guidance documents, calls for ongoing monitoring and ongoing auditing of healthcare programs and operations, including that of the Compliance Office. However, the OIG provides little information that differentiates between these two ongoing efforts. And it’s clear from national surveys that many providers don’t fully understand the differences between the two, says expert Richard Kusserow, CEO of Strategic Management Services. Kusserow, a former head of DHHS, explains what each is intended to oversee.


Ongoing monitoring is a program manager’s responsibility, not the Compliance Officer’s. It includes keeping current with changes in rules, regulations, and applicable laws; developing internal controls, policies, and procedures to comply with them; training staff on these rules; and taking active steps in monitoring or verifying compliance with these new guidelines. Monitoring techniques may include sampling protocols that permit program managers to identify and review variations from an established baseline. Results from this process are often measured numerically as outputs.


Ongoing auditing, by definition, must be performed by parties independent of the areas being reviewed. One primary objective is reviewing the ongoing monitoring by program managers to verify they are meeting their monitoring obligations, validate they are functioning as they were intended, and identify weaknesses in the program that need to be addressed. This validation of the results of ongoing monitoring moves from measuring output to measuring outcomes.

Key takeaways:

For more information relating to monitoring and auditing to evidence compliance program effectiveness, registration is open now for our complimentary webinar featuring Strategic Management Service’s Richard Kusserow, Evidencing Compliance Program Effectiveness. See more insights on healthcare compliance from Richard Kusserow and Strategic Management Services at compliance.com.


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