Healthcare Compliance Programs: The Most Effective Ways to Build One

An article by Kurt Perhach, August 1, 2026

Introduction

Healthcare compliance isn't just a regulatory requirement. It's a practical system for preventing misconduct, reducing risk, and protecting patients, providers, and organizations guided by well-established principles from the Department of Justice. The most effective compliance programs share a common trait. That is, they're designed to work in real-world environments, not just on paper and start with and end with a Tone From the Top and a commitment for leadership to not simply talk the talk, but to also walk the walk.

In my experience, I have created a Top 10 list of the most effective ways to establish a healthcare compliance program that can stand up to internal scrutiny and external expectations.

Rule 1: A Focused TONE FROM THE TOP and a Visible Commitment by Senior Leadership

A compliance program succeeds when leadership sets the tone and backs it with resources.

Effective actions include:

• Appointing a senior compliance leader with authority and independence
• Ensuring the board and executives receive compliance reporting regularly
• Funding compliance activities (training, audits, hotline operations, investigations)
• Demonstrating a "speak up" culture without fear from retaliation or reprisal
• Regular and on-going checks, audits, and trainings to ensure that Senior Leaders are committed to a robust compliance program

Key takeaway: A compliance program must be supported from the top, not delegated as an afterthought.

Rule 2: Perform a Risk Assessment That Actually Drives Decisions

Compliance should be targeted. A strong risk assessment identifies where your organization is most vulnerable.

Best practices:

• Conducting a documented, periodic risk assessment
• Mapping risks to operations (billing, coding, referrals, documentation, privacy, etc.)
• Considering your:
  • service lines
  • payer mix and billing complexity
  • geographic footprint
  • history of audits or allegations
• Using the results to create a prioritized work plan
• Conduct at least an annual top 10 risk assessment where each stakeholder has a vested interest in understanding how their risk impacts the overall culture of the company with targeted and achievable outcomes throughout the year

Key takeaway: If you don't know your risks, you can't build the right controls.

Rule 3: Develop Policies and Procedures That Match Real Work

Policies should be practical, understandable, and aligned with day-to-day operations.

What should be included:

• A compliance code of conduct
• An Employee Handbook
• Annual training requirements so that employees and personnel know and understand the Company's policies
• Role-based policies (e.g., billing/coding, physician relationships, documentation)
• Clear reporting obligations and escalation paths
• Standards for contractors, vendors, and agents
• Job aids that help staff apply policies correctly

Key takeaway: "Policy coverage" is not the same as operational effectiveness.

Rule 4: Implement Training That's Targeted, Ongoing, and Measurable Without Being Overburdening

No one likes training. Far too often we click through those modules just to be done with them and obtain that certificate.

Training must reflect both the risk areas and the roles of individuals.

Most effective training approaches:

• Mandatory training for all employees, plus targeted training for higher-risk roles
• Regular cadence (not one-and-done onboarding)
• Use of real scenarios (coding errors, improper referrals, documentation failures) – we do this all the time in the Army and in Life Sciences
• Language accessibility and accommodations
• Tracking completion and assessing understanding

Key takeaway: Training should change behavior, not just satisfy a checkbox.

Rule 5: Pay for a Strong and Reliable Reporting Hotline

An effective compliance program makes it easy for people to raise concerns and ensures concerns are handled responsibly. Vendors such as NavEx are out there and are worth the money to ensure employees feel comfortable reporting legitimate concerns.

Critical elements:

• A clearly communicated hotline and reporting process
• Anonymous reporting options where feasible
• Confidential intake practices
• Non-retaliation policies that are enforced
• A system for tracking reports, outcomes, and trends

Key takeaway: The value of a hotline depends on trust—and follow-through.

Rule 6: Establish a Robust Investigation Process

Reports and potential violations must be addressed consistently, timely, and properly. They are implemented, tracked, and verified. Depending on the size of your organization, there should be global consistency with key stakeholders discussing cases and events for consistency in disciplinary measures.

Key takeaway: Investigations aren't just fact-finding. They are risk reductions. They are a key part of ensuring employees know their concerns are taken seriously and can drive meaningful and lasting organizational change.

Rule 7: Use Auditing, Monitoring, and Data Analytics to Catch Issues Early

Monitoring is how you turn compliance from reactive to proactive. Let the data work for you, telling the story of progress and growth for Shareholders.

High-impact monitoring examples:

• Claims review and coding audits
• Documentation audits (medical necessity, coverage criteria)
• Referral and ordering monitoring (where applicable)
• Vendor and contractor compliance checks
• Training effectiveness reviews and hotline trend analysis

Key takeaway: If you only rely on complaints, you'll miss silent failure points.

Rule 8: Apply Effective Discipline and Corrective Action

Compliance only works when misconduct has consequences. Consequences should be consistent across geographic footprints and they should have a meaningful ability to fix the problem or problems.

Best practices:

• Consistent discipline aligned with the code of conduct and role impact
• Corrective action plans that address root causes
• Retesting or follow-up audits after remediation
• Documentation of actions taken and results achieved

Key takeaway: Discipline plus remediation builds credibility.

Rule 9: Build an Organizational Culture Where People Speak Up

Policies and training only go so far without trust. Employees have to trust the process, trust that their allegations will be taken seriously and trust that there will be fair and impartial investigations.

Culture-building tactics:

• Leaders model ethical behavior consistently
• Managers reinforce expectations and provide coaching
• Staff feel safe reporting concerns
• Lessons learned are communicated after issues
• Celebrating compliance wins and improvements

Key takeaway: Culture is the "multiplier" for every other compliance control.

Rule 10: Maintain Documentation and Program "Evidence"

In healthcare compliance, proof matters. Regulators and auditors often look for consistent documentation. The FDA expects nothing less.

Document your program elements, including:

• Risk assessments and annual work plans
• Training logs and training materials
• Audit and monitoring reports
• Hotline reports and investigation outcomes
• Corrective action plans and follow-up verification
• Compliance committee minutes and escalation reports

Key takeaway: The strongest programs can demonstrate effectiveness.

Conclusion

By no means does this list compare to a David Letterman top 10 list. But, from my experiences, these are the most critical components of a robust compliance program. The most effective healthcare compliance programs are built on a clear foundation: leadership commitment, risk-based controls, practical policies, targeted training, accessible reporting, thorough investigations, and continuous monitoring. Combined, these elements create a system that reduces risk, improves operational integrity, and most importantly supports better patient outcomes.