Compliance risk 'hot buttons'

The following is a list of questions that CPAs may find useful to frame discussions with organizations regarding potential contract compliance risks:* What self-reporting relationships does the organization have, and what is the total annual amount of dollars flowing from these relationships?

* What types of contracts govern these relationships?

* What types of controls over the performance by the organization's business partners are provided for in the contracts, and do the contracts contain a "right to audit" clause?

* Does the organization carefully review the information and fund flows provided by its business partners under the contracts?

* Does the organization carry out contract inspections of the financial and operational aspects of these relationships on a regular basis?

* Does someone within the organization have full responsibility for all aspects of each commercial relationship, including the operational and financial aspects?

* Are there other control mechanisms that would support the accuracy of information provided by the organization's business partners?

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