Corporate Responsibility
Audit Work Program
PROJECT TEAM (LIST MEMBERS):
Project Timing
Date
Comments
Planning
Fieldwork
Report Issuance (Local)
Report Issuance (Worldwide)
AUDIT OBJECTIVES
The objectives of this audit are to:
 Assess the effectiveness of the corporate responsibility program (CRP) through the measurement of
compliance with benchmark objectives established by Company ABC (ABC) and the corporate
responsibility officer (CRO)
 That measurement of compliance with benchmark objectives established by ABC and the CRO
 Ensure that ABC is continuing to put into practice the seven elements of an effective compliance
program
Time
Project Work Step
Initial
Scope
The scope of the audit will include:

Making inquiries of the CRO

Reviewing various meeting minutes and reports related to the CRP

Reviewing policies and procedures

Evaluating CRP educational activities

Evaluating environmental assessment processes

Assessing routine auditing and monitoring activities

Examining the excluded provider screening processes

Examining the documentation of and response to identified potential
compliance issues

Ensuring compliance with corporate integrity agreement or settlement
agreements, if applicable
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Time
Project Work Step
Initial
Audit Steps
Determine the structure of the CRP within ABC. Document the CRP
committee’s reporting structure, who handles excluded providers, etc. by
preparing the CRO Questionnaire.
Review minutes from all CRP committee meetings for the last fiscal year.
Note the frequency of the meetings and make a determination as to whether
the committee has been active in implementing the CRP Plan (e.g., reports
of auditing and monitoring activities are reviewed by the committee,
potential compliance issues are discussed, etc.)
Obtain the CRO’s annual status report regarding the achievement of the
effectiveness objectives for the year ending (Insert Date) and determine
whether the report was provided to local senior management and the ABC
CRO.
Review minutes from the ABC audit committee or board of directors and
determine whether regular presentations have been made regarding the
status of the CRP.
Integration of Compliance Into Policies and/or Procedures
Determine how compliance-related policies and/or procedures are
integrated into the daily operations of ABC and whether these policies
and/or procedures are documented.
Make an inquiry of the CRO as to whether policies and/or procedures that
specifically address compliance or include compliance-related inferences
have been created or, if in place for more than one year, reviewed and
updated within the last 12 months.
After identifying the policies or procedures that have been created or
updated, document the process used to communicate these new or updated
policies or procedures to associates with a need to know and ensure that
the process appears to be adequate. Review documentation to substantiate
the education provided to the associates.
Education
Obtain a copy of the agenda for the most recent associate orientation.
Ensure that CRP is an item on the agenda and determine the amount of
time spent on CRP during orientation.
Document the process to make certain all associates attend orientation
within 90 days of commencing employment. Determine that the process
appears to be adequate.
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Time
Project Work Step
Initial
Obtain a listing of associates that have attended the last three orientation
sessions. Randomly select ten associates from each local facility that is a
part of ABC and review their CRP acknowledgement cards or other
evidence of CRP education, such as sign-in sheets.
Randomly select ten employees you do not know from each local facility
that is a part of ABC and ask them the following questions:

Have you received CRP training?

Who is the CRO for your facility?

Have you received a copy of the ABC Standards of Conduct?

Are you aware of the Company ABC hotline and its purpose?

What would you do if you suspected a compliance issue?
Document responses to the above questions. Responses may indicate the
effectiveness of the CRP training.
Document the percentage of employees that have received some type of
annual CRP training. At least 95% of the associates should receive some
form of CRP training every year. Evidence may be composed of sign-in
sheets, compliance education reports, reports from the educational tracking
system, etc.
Make an inquiry of the CRO regarding the status of the implementation of
the compliance education. Contact (Insert Name and Contact Information)
for the status of the implementation from the system administrator
perspective and appropriate wording for the report.
Environmental Assessment
Document the process used to perform the (Insert Year) environmental
assessment. Obtain a list of ABC’s focus areas. Note that Company ABC is
no longer required to the use the matrix format to document the
environmental assessment.
Determine that the ABC focus area guidance and the office of the inspector
general work plan were considered during the environmental assessment
process.
Assess whether activities are underway to address compliance risks for
each focus area identified by the ABC. Examples may include self-audits,
external audits, development of policies and procedures, etc.
Hotline/Investigative Reporting
Document the process to investigate hotline company calls. Determine that
the process appears to be adequate.
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Time
Project Work Step
Initial
Obtain a copy of the case disposition log and case disposition log forms.
Ensure the forms were provided to the hotline company in advance of the
call-back date (e.g., 24 hours for Priority A calls, 72 hours for Priority B calls
and 21 days for Priority C calls). If the investigation was not completed as of
the call-back date, ensure that the investigation was completed within a
reasonable amount of time.
Determine that all issues identified via the hotline company were logged,
appropriately investigated, and documented, that a response was given to
the individual reporting the issue, and that a corrective action plan was
developed and implemented, if needed.
Document the process to log, investigate and respond to issues identified
via means other than the hotline company.
Determine that all issues identified via means other than the hotline
company were logged and investigated, that a response was given to the
individual reporting the issue, and that a corrective action plan was
developed and implemented, if needed.
Verify that the quarterly investigation summaries were prepared and
submitted in a timely manner after the end of the quarters ending (Insert
Dates of Quarters).
Corporate Integrity Agreement/Settlement Agreement
Make an inquiry of the CRO as to whether ABC has entered into a
corporate integrity agreement (CIA) or settlement agreement (SA) with
ongoing reporting requirements. If so, contact (Insert Name) to ensure she
is aware of the CIA/SA and has a copy of the agreement.
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