My name is Stan Capela. I am the Corporate Compliance Officer for HeartShare Human Services, as well as the current chair of the American Evaluation Association’s Government Topical Interest Group (GOV TIG). The purpose of this AEA365 is to talk about corporate compliance and its relationship to program evaluation. Also it is an opportunity to highlight significant issues relevant to the Government TIG. This is the first AEA365 as part of a week long conversation on evaluation and government.
Lessons Learned: Several years ago, the federal government created the Office of Medicaid Inspector General’s Office (OMIG) to reduce fraud in Medicaid funded programs. The statute focused on the need for all Medicaid funded programs to establish eight anti-fraud elements. All organizations must have:
1. a corporate compliance policy;
2. corporate compliance program oversight;
3. education and training;
4. effective confidential communication;
5. enforcement compliance standards;
6. auditing and monitoring of compliance activities;
7. detection and response; and
8. whistleblower provisions and protections.
The key is to ensure that systems are in place to provide ongoing monitoring of programs, educate staff on code of conduct, ensure appropriate governance and encourage staff to be cognizant of fraudulent activities and reporting such activities.
Although internal program evaluators conduct ongoing evaluations, the corporate compliance role is one where there is a greater emphasis placed on orchestrating all evaluation activities in a way that reduces fraud, as well as risk to the organization. Further, there also is an emphasis on making sure the corporate compliance officer reports to the governing board and the CEO and President.
Lessons Learned: New York State has placed a great deal of emphasis on OMIG. The agency offers a wide range of webinars and tools. One very useful tool is a checklist to assess organizations’ corporate compliance plans. It is available thru OMIG compliance alert notes at its website: www.omig.ny.gov. As a result of these changes, organizations will place greater emphasis on individuals with program evaluation responsibilities to take on these tasks as part of their normal workload. In addition, this role also re-enforces the importance of ethics as part of the evaluators’ responsibilities since one task focuses on ensuring appropriate ethical conduct throughout the organization.
Hot Tip: Finally, as GOV TIG Chair, I encourage you to attend our business meeting at the AEA annual conference on Thursday November 3rd at 8 am in Huntington B, where you will be inspired by David Bernstein who will reflect on methods to make evaluations more useful and long lasting for research sponsors and stakeholders. If you want to learn more about the TIG or want to play a more active role, contact me at stan.capela@heartshare.org.
The American Evaluation Association is celebrating GOV TIG Week with our colleagues in the Government Evaluation AEA Topical Interest Group. The contributions all this week to aea365 come from our GOV TIG members and you can learn more about their work via the Government TIG sessions at AEA’s annual conference. Do you have questions, concerns, kudos, or content to extend this aea365 contribution? Please add them in the comments section for this post on the aea365 webpage so that we may enrich our community of practice. aea365 is sponsored by the American Evaluation Association and provides a Tip-a-Day by and for evaluators.