You might think about “compliance policies and procedures” as the policies and procedures that structure the compliance program, for example, a reporting and investigation policy.

You might also add policies and procedures for some high-risk compliance areas, such as sanction screening performed by other departments, i.e., HR, credentialing, and vendor management.

You might even further add policies and procedures for additional high-risk areas in operations, for instance, a post-acute care transfer policy.

What is the role of the compliance officer and the compliance committee when it comes to developing these compliance policies and procedures?