A critical element of effective oversight is the process of asking the right questions of management to determine the adequacy and effectiveness of the organization’s compliance program. – Matos et al. (2015)
The governing boards of health care organizations and the compliance officers, auditors, and lawyers who support those boards have a new tool—a guidance document—to help them carry out their compliance plan oversight obligations.
Practical Guidance for Health Care Governing Boards on Compliance Oversight is the result of collaboration between the Inspector General of the Department of Health and Human Services, the American Health Lawyers Association, the Association of Healthcare Internal Auditors, and the Health Care Compliance Association (SCCE, 2015). As stated in the introduction, the document addresses issues relating to a Board’s oversight and review of compliance program functions, including:
- Roles of, and relationships between, the organization’s audit, compliance, and legal departments;
- Mechanism and process for issue-reporting within an organization;
- Approach to identifying regulatory risk; and
- Methods of encouraging enterprise-wide accountability for achievement of compliance goals and objectives.
The report devotes a chapter to each of those issues, each of which provides additional information and links to related resources—a useful starting point.
It encourages boards to use “widely recognized public compliance resources” as benchmarks or baseline assessment tools for their organizations, to include the Federal Sentencing Guidelines, The HHS Office of Inspector General (OIG’s) voluntary compliance program guidance documents, and OIG Corporate Integrity Agreements.
It advises boards to develop a formal plan to stay abreast of “the ever-changing regulatory landscape and operating environment,” to include such things as scheduling periodic updates from informed staff.
It also advises boards to raise their own levels of regulatory and compliance expertise by adding an experienced regulatory or compliance professional to the board, or at least by periodically consulting with one.
Finally, it reminds boards that they should understand how issues and problems in their organizations are reported and elevated to senior management and that they are responsible for encouraging a level of compliance accountability across the organization.
Together, the four collaborating organizations offer expertise in every aspect of health care ethics and compliance. You can retrieve a copy from the link below; consider adding it to your board’s toolbox soon.
Ethical Advocate (EA) provides comprehensive compliance solutions, including ethics training and anonymous incident reporting systems, to millions of users in all sectors. Contact us for more information.
Matos, Katherine, et al. Practical Guidance for Health Care Governing Boards on Compliance Oversight, April 2015.
Society of Corporate Compliance and Ethics (SCCE). “HHS OIG and Industry Leaders Release Joint Guidance for Health Care Boards,” (press release), April 20, 2015. http://www.corporatecompliance.org/Resources/PressReleases.aspx