• The organization exercises due diligence to prevent and detect inappropriate conduct by the Medicaid provider

  • The organization promotes an organizational culture that encourages ethical conduct and is committed to compliance with the law.

  • The compliance program is reasonably designed, implemented, and enforced so that the program is generally effective in preventing  and detecting improper conduct.

Failure to prevent or detect specific offenses does not necessarily mean that the program is not generally effective in preventing and detecting such conduct.