OIG Releases “Practical Guidance for Health Care Governing Boards on Compliance Oversight”

On April 20, the U.S. Department of Health and Human Services Office of Inspector General (OIG) announced the release of a new a guidance document entitled, Practical Guidance for Health Care Governing Boards on Compliance Oversight. “This new educational resource provides practical ideas that boards may consider implementing in their organizations,” states OIG. “The guidance includes processes for identifying risks, tools for improving adherence to program objectives, and effective reporting tools for board meetings.”

The document states that the guidance resulted from the first collaboration of its kind between OIG, the American Health Lawyers Association (AHLA), the Association of Healthcare Internal Auditors (AHIA) and the Health Care Compliance Association (HCCA).

Previous guidance has consistently emphasized the need for Boards to be fully engaged in their oversight responsibility. OIG references three previous guidance documents:

  • OIG and AHLA: Corporate Responsibility and Corporate Compliance: A Resource for Health Care Boards of Directors (2003);
  • OIG and AHLA, An Integrated Approach to Corporate Compliance: A Resource for Health Care Organization Boards of Directors (2004); and
  • OIG and AHLA, Corporate Responsibility and Health Care Quality: A Resource for Health Care Boards of Directors (2007)

View a full list of Board resources on OIG’s website here.

Those who have been involved with the healthcare industry in recent years know that the times have changed since the last guidance was published in 2007. “Given heightened industry and professional interest in governance and transparency issues, this document seeks to provide practical tips for Boards as they work to effectuate their oversight role of their organizations’ compliance with State and Federal laws that regulate the health care industry,” the report states.

The document addresses issues relating to a Board’s oversight and review of compliance program functions, including the: (1) roles of, and relationships between, the organization’s audit, compliance, and legal departments; (2) mechanism and process for issue-reporting within an organization; (3) approach to identifying regulatory risk; and (4) methods of encouraging enterprise-wide accountability for achievement of compliance goals and objectives.

The May issue of Life Science Compliance Update will provide a detailed analysis of “Practical Guidance for Health Care Governing Boards on Compliance Oversight.”

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