OIG Provides Additional Compliance Guidance for Healthcare Governing Boards

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On April 20, 2015, the HHS Office of Inspector General (HHS OIG), in collaboration with the American Health Lawyers Association (AHLA), the Association of Healthcare Internal Auditors (AHIA), and the Health Care Compliance Association (HCCA), released a guidance document on compliance for healthcare governing boards, attorneys, compliance officers, and internal auditors. The insight provided by the government, along with various industry leaders, highlights the cross-disciplinary effort required to create and maintain a culture of corporate compliance for healthcare entities in order to protect the integrity and viability of the nation’s healthcare delivery system.

In light of increasing government fraud and abuse enforcement activity, governing boards have several incentives to build and maintain strong compliance programs that both prevent compliance failures and encourage self-identification of compliance failures for purposes of voluntary disclosure to avoid False Claims Act or civil monetary penalty liability.

Titled “Practical Guidance for Health Care Governing Boards on Compliance Oversight,” the document expands on prior guidance issued by HHS OIG and AHLA in this area and covers the following topics:

  • Expectations for board oversight of compliance program functions
  • Roles and relationships
  • Reporting to the board
  • Identifying and auditing potential risk areas
  • Encouraging accountability and compliance

The issuing organizations make clear that healthcare governing board members should make efforts (1) to increase their knowledge of regulatory risks and the role and operations of their organization’s compliance program in handling those risks, and (2) to ensure the appropriate flow and elevation of reporting of potential issues and problems to management. The guidance acknowledges compliance programs are not uniform, as the design of a compliance program takes into account factors such as the size and complexity of the organization.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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