In developing an effective compliance program, the OIG has identified these seven fundamental elements:

• Implementing written policies, procedures and standards of conduct
• Designating a compliance officer and compliance committee
• Conducting effective training and education
• Developing effective lines of communication
• Enforcing standards through well-publicized disciplinary guidelines
• Conducting internal monitoring and auditing
• Responding promptly to detected offenses and developing corrective action

An example of a Voluntary Compliance Program based on these seven fundamental elements follows on the next several pages.