1. Compliance Management: Make Me Thoughtful
Dr. Kapil Mohan I gargkapilmohan@gmail.com I +91-991-000-4916 Page 1
Increasing litigation/compensation claims and costs associated with it, revenue leakages, greater media scrutiny and
complex legal & regulatory concerns call for greater efficiency in managing the compliance aspect of healthcare
services. In today’s rapidly changing healthcare business environment, there is a marked increase in regulations, greater
focus on fraud and a heightened sense of the need for good governance and risk management of compliance activities.
C-suite executives and corporate boards are under
immense pressure from all stakeholders to achieve
the objectives of the business without
compromising on the quality of services provided,
complying with all legal and regulatory
requirements in a cost-competitive manner.
The need of the hour is a ‘Strategic Partner’ who
can understand all the complexities, analyse trends,
assess organisational practices/core business
operations, and provide cutting edge yet cost-
effective and practical solutions for healthcare providers. One who goes beyond assessing compliance, and adds value
by working with management and improving governance, risk management, and internal controls to achieve strategic
and operational business objectives.
Compliance Management Function:
Compliance management is an independent and objective
function that reviews and evaluates compliance
issues/concerns within the organization, supports CXOs and
ensures management and employees are in compliance with
all applicable policies/procedures/systems, laws, rules, and
regulations of relevant regulatory agencies; that company
policies, procedures, strategies are being followed, and that
behaviour in the organization meets the company’s
Standards of Conduct. Compliance management function -
 Acts as facilitator to the CEO/Corporate Compliance
Committee by monitoring and reporting results of the
compliance/ethics efforts of the company, providing
guidance for the CEO and senior management team on
matters relating to compliance, and providing updates to
the CEO regarding changes to relevant regulations and
compliance measures.
 Acts as an independent review and evaluation body to ensure that compliance issues/concerns within the
organization are being appropriately evaluated, investigated, and resolved.
 Is responsible for providing the executive team with data and information that will guide the strategic direction of
the organization in the context of the current and proposed regulatory environment.
 Develops, initiates, maintains, and revises policies and procedures for the general operation of the Compliance
Program and its related activities to prevent illegal, unethical, or improper conduct in the management of day-to-day
operations of the Business.
Compliance - context

2. Compliance Management: Make Me Thoughtful
Dr. Kapil Mohan I gargkapilmohan@gmail.com I +91-991-000-4916 Page 2
A standardized process followed for internal audit and compliance management may consists of:
 Audit Planning: Quarterly/rolling Audit planning/scheduling. Formulation of audit scope, RACMs, audit
programs/checklists/ICQs, Resource planning for audit assignments.
 Audit Execution: Commencement of audit fieldwork, Coordination with outsourced/co-sourced consultants/auditors,
Maintain a robust audit workflow & issue tracking system, and Audit Alert to relevant Functional Head(s).
 Collaborate and build relationships with leaders across the various functions to review, investigate, resolve and
mitigate any potential regulatory or compliance issues.
 Develop and periodically review and update to management, as directed or requested, to keep the CEO and senior
management informed of the operation and progress of compliance efforts.
 Respond to alleged violations of rules, regulations, policies, procedures, and code of conduct by evaluating or
recommending the initiation of investigative procedures. Develop and oversee a system for uniform handling of
such violations.
 Monitor and, as necessary, coordinate with compliance activities of other departments to remain abreast of the status
of all compliance activities and to identify trends.
 Identify potential areas of compliance vulnerability and risk; develop/implement corrective action plans for
resolution of problematic issues, and provide general guidance on how to avoid or deal with similar situations in the
future.
 Ensure proper reporting of violations or potential violations to duly authorized enforcement agencies as appropriate
and/or required.
 Team Management, work review/documentation, and knowledge sharing.
 Share best practice with relevant functional head(s) and process owner(s) to improve the control environment.
 Implement and manage a “whistle blower” reporting mechanism.
 Institute and maintain an effective compliance communication program for the organization.
 Monitor the performance of the Compliance Program and related activities on a continuing basis, taking appropriate
steps to improve its effectiveness.
Risk-resilient healthcare organisations assume risks profitably while effectively managing the complexities of a rapidly
evolving business and regulatory compliance environment. By integrating risk management, internal control and
compliance systems, management decisions can be made with increased confidence and clarity.
The current business atmosphere of healthcare provider organisations is very complex and competitive. There are
pervasive risks in all facets of operations and an increasing amount of regulatory requirements that the organisation
must comply with. As management sets objectives and identifies processes, a comprehensive risk assessment, internal
audit, and compliance management can help identify risks and prioritise risk responses within operations, as well as
identify potential opportunities. This process will allow the organisation to more efficiently determine where resources
should be allocated.