As the year draws to a close, compliance leaders across the healthcare landscape are once again facing the familiar rush of audits, documentation reviews, and policy updates. But this year feels different. With new CPT codes, ICD-10 revisions, and increased scrutiny on fair market value (FMV) and commercial reasonableness (CR), regulators are signaling that 2026 will demand more diligence, integration, and accountability than ever before.
For compliance officers, general counsel, and physician enterprise executives, year-end is no longer just about 'checking the box.' It’s about ensuring your organization is fully prepared to respond, adapt, and stay ahead of regulatory and operational risk.
Too often, compliance teams view year-end as a time to catch up. However, reactive fixes can leave organizations vulnerable, especially when audit risks and payment model changes accelerate. A proactive compliance readiness review identifies potential gaps before they turn into findings or penalties, ensuring that 2026 begins on a foundation of confidence and control.
Year-end is an opportunity to integrate compliance, legal, and financial frameworks, bridging the gap between regulatory requirements and day-to-day operations.
The 2025 ICD-10 and CPT updates include new codes that directly affect billing, documentation, and audit risk. Now is the time to validate that all updates have been implemented in your EMR and coding systems, audit high-risk service lines—especially evaluation and management (E/M), split/shared visits, and telehealth encounters—and review how your coding and compliance teams communicate to close documentation gaps quickly.
Conducting a targeted documentation audit in Q4 not only identifies training needs but also strengthens your internal audit trail ahead of payer and OIG reviews.
Compensation arrangements often evolve throughout the year, but the supporting FMV and CR analyses may not. Before year-end, reconcile compensation plans against current FMV and CR opinions, confirm that key agreements (PSAs, MSAs, call coverage, and medical directorships) are up to date, and ensure that renewal and amendment timelines are tracked. Supporting valuations should reflect the most recent market data, such as that available through Acuvance DataRise™ Provider Compensation Data Platform.
Regulatory shifts—from data privacy to billing integrity—should trigger updates to your annual training and policy documentation. Evaluate whether your 2025 education plan reflects current OIG priorities and CMS guidance, incorporates scenario-based learning for physicians and managers, and includes refresher sessions for board and leadership teams to reinforce governance oversight. An up-to-date compliance education program is one of the clearest signals of an effective compliance culture to regulators and payers.
Internal audit and monitoring functions are often the first line of defense, but also the first to fall behind amid daily demands. Before closing the year, revisit your audit universe and align it with current risks and reimbursement changes, update monitoring dashboards to track new key performance indicators (KPIs) for 2026, and prioritize follow-up on unresolved audit findings to close the loop before the next reporting cycle. When compliance and finance teams collaborate to integrate operational data into audit plans, risk mitigation becomes measurable instead of theoretical.
A structured effectiveness review helps validate that your compliance program meets OIG expectations for design, implementation, and performance. Use this time to reassess governance structures, evaluate reporting mechanisms, and ensure that corrective actions are tracked, closed, and documented.
Many organizations perform this review internally, but an independent assessment can uncover blind spots and strengthen your risk posture for the year ahead. For more on best practices, refer to the Office of Inspector General’s (OIG) official guidance on Compliance Program Effectiveness.
Every healthcare organization faces unique compliance challenges, but the goal remains the same: sustained integrity, accountability, and operational confidence. Coker’s Compliance and Clinical Advisory teams help hospitals, health systems, and physician enterprises navigate regulatory change through practical, data-informed strategies.
Our year-end readiness reviews evaluate risk across documentation, compensation, governance, and policy structures, providing a clear action plan to begin 2026 prepared, not reactive.
📅 Schedule a Year-End Readiness Consultation
Let’s identify the compliance risks—and opportunities—you can address before January 1. Our experts will guide you through a structured readiness review that aligns with your organization’s size, service lines, and regulatory priorities.