OIG Provides Guidance to Health Care Governing Boards on Compliance Oversight

The Inspector General of the Department of Health and Human Services (“OIG”) — along with the Association of Healthcare Internal Auditors (“AHIA”), the American Health Lawyers Association (“AHLA”), and the Health Care Compliance Association (“HCCA”) — has released a new publication entitled, Practical Guidance for Health Care Governing Boards on Compliance Oversight.

The new publication provides recommendations for governing boards in developing procedures and processes for monitoring a health care organization’s compliance functions, including:

Development of a compliance program whose scope is adequate in relation to the size and complexity of the organization.

Development of a reporting system that can provide a timely response in complying with applicable regulations.

Development of an information system that assists the organization in keeping informed on changes in laws and regulations.

Monitoring by the Board of the interrelationship between the compliance, audit and legal functions to ensure roles and responsibilities are clearly defined and adequate to meet the needs of the organization.

Developing compliance reporting requirements for senior management to provide the Board with timely reports on any pending investigations, results of internal or external audits or possible misconduct.

Developing a process for identifying risk from a variety of sources, including governmental guidance and internal audits.

The new publication makes it clear that health care organization boards are expected to be actively involved in compliance oversight.

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