Most health care organizations have a compliance plan that addresses the OIG’s seven elements, but not all have implemented that plan in a manner that creates a successful compliance program. During this presentation, we will utilize the U.S. Department of Justice’s guidelines for its prosecutors to evaluate the effectiveness of a compliance program to identify opportunities for health care organizations to transition from a written plan to a living and breathing compliance program. Keeping an eye toward process, we will evaluate how an effective compliance program can guide the organization through some of the most common compliance risks – physician relationships, privacy, and accurate claim submission.