What Does It Actually Cost When You Skip Compliance Investment?
In our last post, we talked about why healthcare CEOs push back on compliance budgets and what that really means. Today, we're going to get specific about the costs organizations face when they put off or skip compliance investment.
These aren't "what if" scenarios. These are real expenses organizations absorb every year because the right systems weren't in place when they needed them.
The Four Categories of Hidden Costs
When budgets are tight, compliance work often gets added to someone else's plate or pushed to the back burner. When that happens, four types of costs start to add up, and most executives don't see them coming.
Direct Costs: What You Pay Back and What You Lose for Good
These are the ones you'd expect: fines, penalties, repayments, and sanctions. But there's one cost that catches many leaders off guard, and that's being excluded from federal healthcare programs.
That's not just money out of your pocket. That's the loss of your ability to bring in revenue going forward, and in some cases, it's permanent.
If the OIG excludes you from federal programs, 60 to 70 percent of your revenue goes away right away. You can't bill Medicare. You can't bill Medicaid. You can't bill TRICARE. This isn't a fine you pay and move on from. This can end a business.
We've seen organizations find out they had excluded providers on staff and then realize they had to return every dollar billed while that person was working there. Sometimes that's years of revenue. Sometimes it's millions of dollars. All because sanctions screening wasn't part of their regular compliance process.
Indirect Costs: What You Pay to Clean Things Up
These are the costs that come with responding to compliance matters after they've already surfaced. Legal fees when you need expert help responding to audits. Consulting costs when you need specialized support with OIG self-disclosure or an investigation. Expert auditors when your coding and billing practices are being reviewed.
These expenses can add up to millions, all to deal with something that could have been prevented for much less. We worked with an organization that needed a detailed Anti-Kickback Statute review and consulting support. The cost to respond was over $500,000. The cost to have those arrangements reviewed properly from the start? Around $20,000.
The difference is huge, but it's what organizations pay when they handle compliance after the fact instead of getting ahead of it.
Another example: we see organizations reach their third round of Targeted Probe and Educate audits. The first round is meant to teach. The second round checks whether you fixed the issues. By the third round, Medicare sees you as a bad actor. They either put you on prepayment review or send your case to the OIG for possible fraud investigation.
Prepayment review slows down your cash flow. Normally, you submit a claim and get paid. With prepayment review, you have to send in your claims along with all the paperwork to back them up. Then Medicare reviews everything before they pay you. That means it takes a lot longer to get the money you've already earned.
That's a serious operational setback that compliance systems could have prevented by catching and fixing issues before the first TPE round even started.
Operational Costs: What You Lose When Leaders Stop Leading
This is what most executives miss entirely. Someone is going to handle compliance work. If you don't have a team for it, the work falls on your COO taking time away from operations, your CFO stepping away from financial strategy, or your head of revenue cycle stepping away from the work that brings money in. That means they're stepping away from the work you hired them to do.
You hired these people for their specialized expertise. When you pull them into compliance matters, you're removing them from the work that actually generates value for the organization. Your COO should be focused on running operations well. Your CFO should be managing finances and planning ahead. Your revenue cycle director should be making sure claims go out clean and money comes in. When they get pulled into compliance investigations, audit responses, or writing policies, that core work doesn't get done.
That's a real cost that never shows up on a budget line but affects your business every day. It's also why the OIG warns against giving compliance duties to these roles. Their primary responsibilities can create competing priorities when compliance matters come up.
Reputational Costs: What You Pay to Rebuild Trust
These costs build over time and are hard to recover from. The OIG and DOJ make enforcement actions public. Once your organization's name shows up in those press releases, patients start to wonder about their choice of provider. Hospital systems rethink partnerships. Payers look for other options.
It takes seven positive interactions to make up for one bad experience. When your reputation takes a hit from a compliance matter, rebuilding trust takes a lot of time and money.
We've seen organizations spend years and significant marketing dollars trying to bounce back from a single compliance settlement. Meanwhile, their competitors who invested in compliance from the start are building partnerships, attracting patients, and growing their share of the market.
Rebuilding your reputation costs far more than keeping compliance systems in place that prevent these situations to begin with.
Real Examples of What These Costs Look Like
We worked with an organization that went on an acquisition spree, buying companies within their specialty quickly to drive growth. Smart strategic move. The issue? They skipped compliance due diligence on those acquisitions.
When you buy a company through a stock purchase, you take on their liability. The OIG can look back seven years for False Claims Act violations. Years after those deals closed, people started reporting things that happened before the purchase.
Eight corporate integrity agreements later, this organization had spent millions fixing compliance issues from the companies they bought. All of it could have been avoided with proper due diligence upfront. The cost comparison? About $100,000 for a thorough compliance review versus millions on the back end.
The Pattern We See Over and Over
Organizations that put off compliance investment end up paying far more in these four cost areas than they would have spent building the right systems from the start.
The executives who see this early don't think of compliance as competing with other priorities. They see it as protecting what they've already built and making room for the growth they're planning.
In our next post, we'll look at what compliance investment actually delivers when done right. Beyond avoiding these four cost areas, there are three specific returns that make compliance a strategic advantage, not just a necessary expense.
You understand what putting off compliance costs. Now it's time to see what investing in it delivers.
Ronan Healthcare Compliance partners with healthcare CEOs and executive leaders to build compliance programs that protect operations and enable confident growth. Ross Ronan brings over 20 years of experience in healthcare operations, compliance, and executive leadership.
This post is part of a series on compliance investment for healthcare CEOs. Previous posts cover why CEOs resist compliance budgets and the hidden costs of that resistance.