Building a Compliance Program in a Virtual Care Center

Express Talk

April 16, 2019 | 10:15 a.m. – 11:00 a.m. CDT

Using the seven elements of the Department of Health and Human Services’ (HHS) Office of Inspector General’s (OIG) Effective Compliance Program, as outlined in the Federal Sentencing Guidelines, Legal Counsel and Compliance Manager for Mayo Clinic’s Center for Connected Care will discuss the establishment of a compliance program that is integrated into its telemedicine center. The Associate Administrator for Connected Care will discuss the value in partnering with Legal and Compliance to integrate best practices within the clinical practice and operational processes.

In addition to being required by the Department of Health and Human Services’ (HHS) Office of Inspector General (OIG), an effective compliance program is important for other reasons. An integrated compliance program will bridge the legal requirements with program operations through the incorporation of an effective compliance program into the day-to-day operations. This approach makes compliance a regular part of doing business. Once the program is fully integrated, regulatory compliance increases because it becomes part of the program’s daily practices.

In addition, in the event of regulatory gaps, an effective compliance program will help to reduce the degree or extent of liability by demonstrating to regulators the good faith efforts to identify, mitigate and prevent non-compliant behaviors and activities. The development of a sustainable and scalable telemedicine services can be decelerated by a multitude of rapidly-changing legal and regulatory requirements on both state and federal levels. Often the laws and guidance are confusing and outdated because they were drafted at a time when telemedicine did not exist, making them difficult to interpret and apply to today’s new modalities of health care. An embedded practice-oriented compliance program helps to operationalize the regulatory requirements while managing an organization’s risk.


  • Megan Olson, JD, International Compliance & Privacy Officer/Connected Care Compliance Manager, Mayo Clinic
  • Greg Anthony, Associate Administrator, Mayo Clinic
  • Page Underwood, JD, Legal Counsel, Mayo Clinic