Assessment and Investigations

Although compliance risks apply to all organizations, the degree of risk posed will vary. A comprehensive risk assessment helps to identify potential risks, determine the level of risk to the organization, and develop a plan for maximizing your resources to address risk. The risk assessment identifies where internal controls exist and areas for which additional controls are required to mitigate risk.

Athena’s Risk Assessments include, but are not limited to:

• Evaluation of OIG Work Plan and recent government enforcement actions
• Interviews with senior leadership and directors of high-risk departments
• Review of recent audit reports, monitoring activity, and denial trends
• Evaluation of PEPPER reports and RAC activity

Athena will work with your organization to develop a prioritized work plan for addressing identified risks. Athena can also assist with determining the scope of proposed audits or developing performance improvement plans.

The Office of Inspector General’s Compliance Program Guidance recommends periodic review of an organization’s Compliance Program to assess whether the seven elements of an effective Program have been satisfied. Athena provides independent Compliance Program Effectiveness Assessments to help provider organizations demonstrate their commitment to compliance while identifying potential areas for improvement.

Athena’s Compliance Program Effectiveness Assessments involve a comprehensive review of Compliance Program documents and organizational practices. The assessment includes, but is not limited to:

• Review of Compliance policies and procedures;
• Review of Compliance education and training materials;
• Review of Compliance Committee materials and meeting minutes;
• Review of compliance updates provided to the Board;
• Interviews with leadership and individuals in high-risk departments;
• Review of investigation processes and documentation; and
• Review of risk assessment and work plan development process.

Athena provides your assessment results and recommendations in a comprehensive report, as well as an executive summary and customized action plan.

Conducting a thorough investigation of alleged compliance violations can be challenging and time-consuming. Athena provides Compliance Investigation services to help ease the burden. Whether you are looking for an independent investigation or assistance in conducting your own investigation, our Partners can assist you with the Compliance Investigation process.

Investigations entail:

• Evaluating the complaint or allegation;
• Assessing whether an investigation should be done under the direction of legal counsel;
• Developing an investigative plan of action, including determining appropriate department involvement;
• Interviewing complainants, witnesses, and other relevant parties;
• Documenting the process and all relevant information;
• Developing a corrective action plan; and
• Drafting investigative reports and work with legal counsel to draft any required disclosures.