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OIG Compliance Guidance for Healthcare Governing Boards

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The Office of Inspector General has released a new document for health care Governing Boards that provides guidance for proper compliance oversight.  The document reiterates the Board’s responsibility to oversee and review an organization’s compliance program.  It helps Boards understand that oversight is a serious responsibility designed to undercover potential risks and compliance issues. 

Governing Boards of healthcare facilities must ask the right questions and know what is being done to ensure that their organization is in compliance with government rules and regulations and reducing risk.   

The document addresses four main areas related to a Board’s oversight of compliance program functions:

  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 objective

The document concludes:

“A health care governing Board should make efforts to increase its knowledge of relevant and emerging regulatory risks, the role and functioning of the organization’s compliance program in the face of those risks, and the flow and elevation of reporting of potential issues and problems to senior management.  A Board should also encourage a level of compliance accountability across the organization.”

For years the OIG has stressed the importance of Board oversight and review of the compliance programs at health care facilities.    With the release of this latest guidance, the government is telling health care facilities what is expected from the Board in meeting their compliance obligations.

Typically the release of a health care guidance document means that the OIG has identified a problem area and is placing that area under scrutiny.  The next step is often a series of audits to determine if specific facilities are in compliance.  Health care Governing Boards would be wise to carefully review the guidance to see how it applies to their facility, to ensure that their oversight is thorough and to implement appropriate recommendations.

You can download the document here.