In this episode, Rose and Michael dive into one of the most overlooked, but essential, components of every compliance program: documenting your decision-making.
Whether you’re updating a policy, interpreting payer guidance, or responding to a complaint, every one of those actions is a decision. And in the eyes of regulators, payers, and auditors, those decisions don’t truly exist unless they’re documented.
Rose and Michael break down why documenting your reasoning isn’t about creating busywork, it’s about creating a defensible narrative that shows diligence, mitigates risk, and builds trust with stakeholders.
Resources:
U.S. Department of Justice’s Evaluation of Corporate Compliance Programs (updated Sept. 2024)
U.S. Office of Inspector General, Health and Human Services, General Compliance Program Guidance (Nov. 2023)
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