Healthcare Organization Boards’ Responsibilities for Compliance Plan Oversight

The governing board of any health care organization has critical oversight responsibilities for the organization’s compliance plan.  To help boards meet these responsibilities, the U.S. Department of Health and Human Services Office of Inspector General (OIG) has issued a new practical guide outlining health care boards’ compliance obligations.   The guide, entitled “Practical Guidance for Health Care Governing Boards on Compliance Oversight” was created by the OIG in collaboration with the American Health Lawyers Association (AHLA), the Association of Healthcare Internal Auditors (AHIA) and the Health Care Compliance Association (HCCA).

While not intended to set particular standards of conduct, the guide attempts to provide practical guidance to help governing boards of health care organizations understand and address their compliance responsibilities.   The guide emphasizes the practical, with sections on the OIG’s expectations for board oversight of compliance programs and the interrelationship of audit, compliance and legal functions.  The guide also addresses mechanisms for identifying risks and reporting issues to the board, along with methods of encouraging accountability to achieve compliance objectives.

Although not every compliance measure addressed in the guide may be appropriate for every organization, every board may benefit from additional insight to the regulators’ compliance expectations.  The guide can be found at the following link: https://oig.hhs.gov/compliance/compliance-guidance/docs/Practical-Guidance-for-Health-Care-Boards-on-Compliance-Oversight.pdf

© 2015 Houghton Vandenack Williams

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