Yesterday, the U.S. Department of Health and Human Services Office of Inspector General (OIG), in conjunction with the American Health Lawyers Association (AHLA), the Association of Healthcare Internal Auditors (AHIA) and the Health Care Compliance Association (HCCA), announced the release of a guidance document titled, “Practical Guidance for Health Care Governing Boards on Compliance Oversight” (2015 Guidance). The 2015 Guidance supplements previous guidance documents issued by the OIG in 2003, 2004 and 2007 related to oversight by boards of directors (BOD) for health care companies.
In addition to discussing BOD oversight expectations, the 2015 Guidance defines and discusses the relationship between the compliance, legal, internal audit, human resources (HR) and quality functions of an organization. The 2015 Guidance also tackles tough topics related to reporting to the BOD, identifying and auditing potential risk areas, and compliance accountability.
The 2015 Guidance document should be carefully reviewed by directors of health care companies, as well as compliance, legal, audit, quality and HR professionals.
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