Corporate compliance: critical to organizational success.

Operation Restore Trust (ORT) has focused increased governmental attention on health care fraud and abuse activities, making it more costly to be noncompliant, and thus has led to significant behavioral changes within the health care industry. Initially five states (California, Florida, Illinois, New York, & Texas) were included in the 1997 ORT pilot program. This has been expanded to include Arizona, Colorado, Georgia, Louisiana, Massachusetts, Missouri, New Jersey, Ohio, Pennsylvania, Tennessee, Virginia, and Washington. The author presents a road map for developing of a compliance program that includes suggested strategies for staff training in anticipation of heightened scrutiny of compliance standards and procedures. Effective Corporate Compliance Programs (CCPs) should include policies and procedures and monitoring systems that can provide reasonable assurance that fraud, abuse, and systematic billing errors are detected in a timely manner.