Risk Assessment
U.S. Federal Sentencing GuiDelines
The U.S. Federal Sentencing Guidelines provide the additional note of a periodic risk assessment. This can be understood as a separate element or as part of other elements and is also related to quality improvement.
Visual Format
A hybrid design process can be used to create risk assessments that detail the impact or consequences of risks faced by an entity and may incorporate elements of design for ease of use. For greater simplicity and focus, the top risks can be identified in a visual format, which would then form the basis for risk mitigation, including auditing, monitoring, and corrective action plans related to quality improvement. Controls may also be designed within algorithms, to prevent noncompliance from occurring.
Customization
Entities should customize and add further elements to their compliance programs based on their industry, culture, and mission beyond the OIG Guidance and the additional risk assessment element from the US Federal Sentencing Guidelines. The OIG report “The Organizational Sentencing Guidelines: Thirty Years of Innovation and Influence,” states that it describes the “minimum requirements for an effective compliance and ethics program” (page 33).