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Abstract
The Office of Inspector General in its compliance guidance provides the answer to program effectiveness and provides two methods for providing credible evidence of the effectiveness of compliance programs: 1. independent assessments of the compliance program effectiveness, and 2. using anonymous surveys to evidence compliance program effectiveness. In both cases, having the work done by parties independent of the compliance program is essential. It is far easier for an outside party to advocate compliance program needs than having the same message coming only from the compliance officer, which might be viewed as only self serving. The two major methods of evaluating compliance program effectiveness can provide convincing metric evidence of compliance program effectiveness. It also can be critical in engaging oversight committee interest that can, in turn, translate to support and empowerment for the compliance officer. It will provide a framework whereby individual reports relating to the program operations can be better understood and made relevant. Consideration might be given to alternating annually between independent assessments and surveys.