12 min
OIG Guidance for Boards Regarding Compliance 31 Days to a More Effective Compliance Program
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- Business
The OIG white paper “Practical Guidance for Health Care Governing Boards on Compliance Oversight” (OIG Guidance), provides an excellent road map for thinking about how to structure a Compliance Committee for your Board and a Board’s obligations. As an introduction, the OIG Guidance states that a Board must act in good faith around its obligations regarding compliance. This means that there must be both a corporation information and reporting system and that such reporting mechanisms provide appropriate information to a Board. It states: The existence of a corporate reporting system is a key compliance program element, which not only keeps the Board informed of the activities of the organization, but also enables an organization to evaluate and respond to issues of potentially illegal or otherwise inappropriate activity.
The OIG Guidance sets out four areas of Board oversight and review of a compliance function:
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 OIG Guidance is an excellent review for not only compliance professionals and others in the healthcare industry but a good primer for Boards around their own duties under a best practices compliance program. The U.S. Sentencing Guidelines, the Hallmarks of an Effective Compliance Program, the OIG Guidance, and OIG Corporate Integrity Agreements can be used as baseline assessment tools for Boards and management in determining what specific functions may be necessary to meet the requirements of an effective compliance program.
Three key takeaways:
Information flow up to the Board is critical.
Compliance should be institutionalized in your company as a way of life.
A Board needs to consider all risks.
This month's sponsor is Affiliated Monitors, Inc.
Learn more about your ad choices. Visit megaphone.fm/adchoices
The OIG white paper “Practical Guidance for Health Care Governing Boards on Compliance Oversight” (OIG Guidance), provides an excellent road map for thinking about how to structure a Compliance Committee for your Board and a Board’s obligations. As an introduction, the OIG Guidance states that a Board must act in good faith around its obligations regarding compliance. This means that there must be both a corporation information and reporting system and that such reporting mechanisms provide appropriate information to a Board. It states: The existence of a corporate reporting system is a key compliance program element, which not only keeps the Board informed of the activities of the organization, but also enables an organization to evaluate and respond to issues of potentially illegal or otherwise inappropriate activity.
The OIG Guidance sets out four areas of Board oversight and review of a compliance function:
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 OIG Guidance is an excellent review for not only compliance professionals and others in the healthcare industry but a good primer for Boards around their own duties under a best practices compliance program. The U.S. Sentencing Guidelines, the Hallmarks of an Effective Compliance Program, the OIG Guidance, and OIG Corporate Integrity Agreements can be used as baseline assessment tools for Boards and management in determining what specific functions may be necessary to meet the requirements of an effective compliance program.
Three key takeaways:
Information flow up to the Board is critical.
Compliance should be institutionalized in your company as a way of life.
A Board needs to consider all risks.
This month's sponsor is Affiliated Monitors, Inc.
Learn more about your ad choices. Visit megaphone.fm/adchoices
12 min