Governing boards of health care organizations now have new guidance to carry out their oversight responsibilities. The guidance also is intended for internal auditors, compliance, and legal executives that report to those boards.
The guidance, published April 20, was developed in collaboration with the Association of Healthcare Internal Auditors (AHIA), the American Health Lawyers Association (AHLA), the Health Care Compliance Association (HCCA), and the Office of Inspector General (OIG) of the Department of Health and Human Services (HHS).
“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, as well as the performance of those who develop and execute that program, and to make compliance a responsibility for all levels of management,” the guidance stated.
The document provides practical ideas that boards may consider implementing in their organizations, including processes for identifying risks, tools for improving adherence to program objectives, and effective reporting tools for board meetings. The document suggests diverse tools and tips that boards of varied sizes and resources may use.
Specifically, the document addresses issues relating to a board’s oversight and review of compliance program functions, including the:
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 recommendations presented in this document are intended to assist boards with the performance of those activities that are key to their compliance program oversight responsibilities,” the guidance stated. “Ultimately, compliance efforts are necessary to protect patients and public funds, but the form and manner of such efforts will always be dependent on the organization’s individual situation.”
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