What does the HCCA identify as two critical components of a compliance program?

The identification of structural and substantive components as critical elements of a compliance program aligns with the emphasis on building a robust foundation for compliance within an organization. Structural components typically refer to the organizational framework that includes governance, roles, resources, and processes necessary to support an effective compliance program. This encompasses establishing a dedicated compliance officer, forming a compliance committee, and creating policies that reflect the organization’s ethical standards and obligations.

Substantive components, on the other hand, relate to the actual practices and implementations that give life to the compliance program. This includes adherence to regulations, operational policies, risk assessments, and monitoring activities. Each of these components plays a crucial role in ensuring that the compliance program is functional and effective, creating an environment that encourages adherence to laws and regulations, thereby minimizing risks associated with non-compliance.

In contrast to the other options, which touch upon various aspects of a compliance program, the focus on both structural and substantive elements underscores the necessity of integrating governance and ethical practices to establish a comprehensive compliance framework. This dual focus ensures that compliance is not just an administrative function but is woven into the very fabric of the organization’s operations and culture.