| Course | HI545 Health Care Compliance |
|---|---|
| Unit | Unit 10 |
| Paper type | Program effectiveness review |
| Length | About 1,120 words, 7 pages double-spaced |
| Format | APA 7 student paper |
| School | Purdue University Global |
| Program | MS in Health Informatics |
| Updated | October 2026 |
Free sample paper for HI545 Unit 10
Nine Found Inside, Two Found Outside: A Unit 10 Program Effectiveness Review of a Compliance Program's First Year With an Acquired Practice
[Student Name]
Purdue University Global
HI545: Health Care Compliance
Unit 10 Program Effectiveness Review
[Instructor Name]
[Date]
Esterline Health, the practice and every count are composite; the guidance cited is real.
Purpose and Method
This review answers the question federal prosecutors and the OIG both ask of a compliance program: does it work in practice, not only on paper (U.S. Department of Justice, 2024)? It covers the twelve months after Esterline Health acquired the six-physician pulmonology and sleep medicine practice. For each of the seven elements in the general compliance guidance (Office of Inspector General [OIG], 2023), the review sets out the evidence of operation, the problems the element caught, how they were resolved, and what remains unproven. Measures were chosen from a resource guide on compliance effectiveness developed by the OIG with compliance professionals, which encourages organizations to pick measures that fit their own risks rather than adopting every one (Office of Inspector General & Health Care Compliance Association, 2017). The single most telling measure is where problems were found. A program that finds most of its own problems is working; one whose problems are found by payers, regulators or whistleblowers is not.
The Eleven Problems
Found by the program:
1. The expired pulmonary rehabilitation directorship with an unsigned raise, found in the acquisition compliance review.
2. Time-based office visit levels inflated by a template field, found by the quarterly coding audit.
3. An excluded agency sleep technologist, found by the first monthly roster screen.
4. Nurse practitioner visits billed incident-to when the conditions were not met, found by the billing risk assessment.
5. Pulmonary rehabilitation sessions continued after treatment plans lapsed, found by the risk assessment and confirmed by a worklist.
6. Patients booked as new when they had been seen by Esterline's own pulmonologists, found by the risk assessment.
7. Credit balances held past sixty days, found by the new weekly report.
8. Scrubber overrides without documented reasons, found by the new override report.
9. A manager who delayed a coder's concern for three weeks, found through the intake log after manager training.
Found by outsiders:
10. Sleep studies performed on unsigned orders, found by a Medicare contractor's targeted review of home sleep tests.
11. Modifier 25 appended to visits on the same day as spirometry without a separately documented service, found by a commercial payer's audit.
Nine of eleven problems were found by the program itself, but both outside finds trace to risks the program had already named and then ranked too low to act on.
Element-by-Element Review
Written policies and procedures. Evidence: the revised screening policy, the corrective action plan template and the change to the office visit template are in effect, and 96 percent of the practice's staff acknowledged the updated code. Caught: none directly, which is expected for this element. Unproven: whether staff know the policies beyond acknowledgment. Compliance officer and committee. Evidence: the committee met monthly, minutes record decisions with dates and owners, and the compliance officer reported to the board's audit committee each quarter. Caught: the committee forced dates onto the directorship disclosure after delays. Unproven: whether the officer has enough staff, since the coding audit team was stretched across two plans. Training and education. Evidence: all 64 managers completed the live session; all clinicians passed the time-statement check. Caught: indirectly, problem 9 surfaced because a trained manager recognized a colleague's delay. Measure: the share of manager-heard concerns reaching the compliance office within one business day rose from 31 percent to 74 percent, below the 80 percent target. Effective lines of communication. Evidence: concerns rose from 58 to 81, which the review reads as greater trust rather than more wrongdoing, since the share later substantiated held steady. The hotline received its first calls from the acquired practice, four in the year. Caught: problem 9. Auditing and monitoring. Evidence: four quarters of coding audits, monthly exclusion screens with quarterly tests of the screening, and weekly credit balance and override reports. Caught: problems 2, 3, 7 and 8. Gap: the audit sample checked office visit levels only; modifier 25 was added to the risk list in the spring but not to the audit sample until after the payer's audit. Enforcement and discipline. Evidence: one written warning to the manager in problem 9 and a contract action against the staffing agency in problem 3. Unproven: consistency across departments, since only two actions were taken. Response and corrective action. Evidence: corrective action plans for problems 2 and 4 with dated steps; refunds for problems 2, 3, 5, 6 and 7; a disclosure for problem 1. Caught: the re-audit for problem 2 passed with two of thirty visits overcoded.
Tracing the Outside Finds
Problem 10, unsigned sleep study orders, was named in the Unit 5 risk assessment as R4 with a priority of 18, near the bottom. The recommended control, a weekly unsigned-order report, was planned for the year's last six months and had not started when the contractor's review arrived. The gap was not identification but ranking: a low score sent a known risk to the back of the queue. Problem 11, modifier 25 use, was scored R9 at 36. The control was to add modifier 25 to the quarterly audit sample, which did not happen until the fourth quarter. A commercial payer found the pattern first. Both outside finds share one cause: the program treated its risk ranking as a schedule, so risks below the top few waited months for any control at all. That ranking was meant to order the work, not to postpone the rest of it.
Recommendations for Year Two
1. Every risk on the assessment receives at least a monitoring control within ninety days, regardless of its priority number.
2. The audit sample expands to include modifier use and order signatures, with an added reviewer to support it.
3. Manager training continues, with a target of 80 percent within one business day and a department-level report.
4. The compliance office receives one additional analyst, because two audit plans and monthly screens exceeded current staff.
5. The ratio of internal to external finds goes to the board quarterly as the program's headline measure.
Conclusion
In its first year with the acquired practice, the program found most of its own problems, repaid what it owed and changed the conditions that produced the errors. Its weakness was speed below the top of the risk list. Year two should be judged by whether the next outside find, if there is one, comes from a risk the program had never identified, rather than one it identified and set aside.
References
Office of Inspector General. (2023). General compliance program guidance. U.S. Department of Health and Human Services.
Office of Inspector General & Health Care Compliance Association. (2017). Measuring compliance program effectiveness: A resource guide. U.S. Department of Health and Human Services.
U.S. Department of Justice. (2024). Evaluation of corporate compliance programs. Criminal Division, U.S. Department of Justice.
The Purdue Global HI545 Unit 10 instructions
The tenth unit usually asks you to evaluate whether the compliance program in the case is effective and to recommend improvements. Expect to review each program element against evidence, use measures rather than impressions, identify gaps and propose changes for the next year. Many instructors want the review to draw on federal guidance and on a recognized effectiveness framework. Comparing problems found by the program with those found by outsiders is a strong measure where the case allows it. Avoid declaring the organization compliant; an effectiveness review judges detection, correction and documentation. Cite the OIG's general guidance, the resource guide on measuring effectiveness and, if useful, the Justice Department's evaluation questions. Six to eight pages is a common length. Recommendations should be specific and tied to what the review found.
How this HI545 Unit 10 example is built
Purpose and method come first, framing the question as whether the program works in practice and choosing measures from a recognized guide. The eleven problems are listed in two groups, nine found by the program and two by outsiders, and the highlighted sentence observes that both outside finds were risks already named. Each of the seven elements then receives the same three questions: evidence of operation, what it caught and what is unproven. A margin note explains why the repeated questions keep the review honest. Measures appear where they exist, such as the one-day reporting rate and the rise in concerns. A section traces both outside finds to their risk scores and to delayed controls, and a second note marks that tracing. Five recommendations for year two follow, and the conclusion names the test for next year.
HI545 Unit 10 rubric: what earns full points
Effectiveness reviews are usually scored on evidence and diagnosis. The largest share of the points goes to evaluating each element with measures drawn from the case rather than restating what the element is. Identification of gaps earns credit when each gap is traced to a cause. Recommendations are judged on whether they address those causes and can be checked next year. Use of guidance and effectiveness frameworks has its own row, rewarded when applied rather than summarized. Organization, clarity and APA citation complete the rubric. Points are often lost by rating every element as effective without evidence, by ignoring external findings, by treating more hotline calls as automatically bad, or by recommending a complete overhaul when the data point to two specific gaps.
HI545 Unit 10 help: mistakes that cost points
Reviews on this topic often come back as summaries of the year rather than evaluations. Each element needs evidence, not a description. Another frequent gap is ignoring the problems outsiders found, which are the clearest signs of where a program is blind. Some writers read a rise in reported concerns as a sign of more wrongdoing without checking substantiation. Recommendations are often generic, such as increase training. Others claim the organization is now compliant, which no review can show. When your case reports other results, share it together with the units you already submitted, and a review measuring each element against your own evidence, with outside finds traced to a cause, can be prepared.
Get an HI545 Unit 10 example written to your instructions
Effectiveness reviews in the final unit often draw on figures scattered through earlier assignments. Collect whatever the course supplied, audit results, hotline counts, training measures or a year-end scenario, and attach the rubric. The review will rate that program on its own detections. Delivered within 24-48h, the first custom sample carries no fee. The paper above is an original model document written by our desk, not a submitted student paper and not an official Purdue University Global document.
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HI545 Unit 10 questions, answered
Why are external findings treated as the most important rows?
Because they show where the program was blind. An issue the program found itself confirms that some element worked; an issue a payer or regulator found first shows an element that did not. The sample reads each external find back to the element that should have caught it, then builds next year's audit plan from those gaps.
Is a rising number of hotline reports good or bad?
Usually good in a new program, since it suggests people know the channel and trust it. It becomes worrying if substantiated findings rise in the same areas year after year, which would mean detection works and correction does not. The sample reads the increase alongside time to correction and repeat findings rather than as a success on its own.
Does the review say whether the organization complies?
No. An effectiveness review judges whether a program detects, corrects and documents problems; it does not certify compliance, and no program can guarantee it. The sample rates each element as operating, partly operating or not yet shown on composite evidence and asserts nothing about any real organization.
Where can I find a free HI545 Unit 10 sample paper?
The complete Unit 10 review is posted on this page, with eleven problems, an element-by-element evaluation, two traced outside finds and five recommendations.
What do the two outside finds have in common?
Both were risks the program had named in its assessment but ranked low, so their controls were scheduled months away when outsiders found them.