CO-Q Training-Elements 5, 6 & 7

Course overview

Element 5: Auditing, Monitoring, and Internal Reporting Systems: This elements module addresses: Protect anonymity and confidentiality within legal and practical limits. Publicize the reporting system to all workforce members, vendors, and agents. Ensure monitoring occurs for violations of laws and regulations. Conduct organizational risk assessments. Develop work plan based on risk assessment. Ensure that reporting system(s) exist to enable employees to report any noncompliance (e.g., hotline). Respond to compliance concerns expressed by employees through internal reporting. Ensure the existence of procedures for monitoring adherence to compliance policies and procedures. Conduct compliance audits. Analyze compliance audit results (e.g., track, trend, benchmark). Develop an annual compliance audit plan. Evaluate results of audits conducted by external entities. Monitor that retaliation for reporting compliance concerns has not occurred. Recognize need for attorney consultation in the auditing/monitoring process. Employ auditing methodologies that are objective and independent. Determine sampling methodology consistent with circumstances. Ensure a timely response is made to reported compliance concerns. Monitor managements implementation of corrective action plans. Provide timely feedback to management on compliance concerns based on audit results Element 6: Counseling and Discipline: This elements module addresses: Recommend disciplinary action when noncompliance is substantiated. Promote discipline proportionate to violations. Promote discipline consistent with policies and procedures. Verify that discipline is enforced consistently throughout all levels of the organization. Monitor for consistent documentation of disciplinary action. Recommend action for individuals and entities that have been excluded from government programs. Verify that compliance related violations are addressed in disciplinary policies. Coordinate with management that timely disciplinary action is taken. Verify that disciplinary action is reported to the appropriate regulatory body when required. Element 7: Investigations and Remedial Measures: This elements module addresses: Communicate noncompliance through appropriate channels. Ensure development of corrective action plans in response to noncompliance. Monitor the effectiveness of corrective action plans in response to noncompliance. Recommend modification of corrective action plans. Ensure remedial efforts are implemented to reduce risk. Cooperate with government inquiries and investigations. Investigate matters related to noncompliance in a fair, objective, and discrete manner. Coordinate investigations to preserve privileges, as applicable. Ensure records are maintained from compliance investigations. Ensure documents relevant to an investigation are preserved. Facilitate independent investigations when necessary. Ensure investigation personnel have the necessary skill sets.