OIG issues Practical Guidance Tool for Health Care Board Oversight

Tuesday, April 21, 2015

Speaking at the annual Health Care Compliance Association (HCCA) Compliance Institute on Monday, April 20, 2015, Department of Health & Human Services (HHS) Inspector General Daniel Levinson announced the issuance of a new tool for healthcare boards, entitled Practical Guidance for Health Care Governing Boards on Compliance Oversight, a collaborative effort of HHS, the American Health Lawyers Association, the Association of Healthcare Internal Auditors and HCCA.

The new Guidance takes into consideration past compliance tools for healthcare boards and offers practical tips to assist boards in carrying out their compliance program oversight responsibilities. The Guidance gives boards information they can use in directing their organization's compliance with applicable Federal and state laws and regulations affecting the health care industry, as well as in better understanding of their organization's compliance program functions, including the: (1) interplay between the organization’s audit, compliance, and legal departments; (2) reporting mechanisms and processes within the organization; (3) regulatory risk assessment approaches; and (4) ways to achieve compliance goals and objectives through enterprise-wide cooperation.

While compliance tools have been publicly available through the Office of Inspector General (OIG), and numerous other sources, the Guidance offers real-world best practices and encourages boards to utilize those public resources that will aide in their oversight efforts. In addition to the traditional tools for compliance, i.e., the United States Sentencing Guidelines and OIG voluntary corporate program guidance, the Guidance urges boards to review OIG Corporate Integrity Agreements for currently identified risk areas. This newest Guidance will assist not only boards and their compliance and audit committees, but also compliance officers, auditors, and others to support a "corporate culture of compliance."

This latest release provides useful information for all healthcare organizations, large or small. The Guidance recognizes (as do prior OIG materials and other resources) that effective compliance programs are not a “one size fits all” approach. Boards should focus on programs that are within the means of their organizations, assess risk, and develop appropriate plans in response. Compliance programs should be reviewed, evaluated, and updated on a regular basis. For more information about this latest Guidance, or assistance in developing, implementing, or reviewing healthcare compliance programs, you can contact the author of this alert or any member of Butzel Long’s Health Care Industry Group.

Debra Geroux
248.258.2603
geroux@butzel.com

Mark Lezotte
313.225.7058
lezotte@butzel.com

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