A 2015 report from The Office of Inspector General (OIG), Department of Health and Human Services, entitled “Practical Guidance for Health Care Governing Boards on Compliance Oversight” provides an excellent roadmap for today’s compliance function when thinking about how to structure a compliance committee for your board and a board’s obligations.
It is a great guide for CCOs to follow and lays out some best practices that the Man From FCPA highly recommends. As an introduction, the OIG guidance states that a board must act in good faith around its obligations regarding compliance and sets out four areas of board oversight and review of a compliance function; “(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.”
