The Office of Inspector General (“OIG”) of the U.S. Department of Health and Human Services (“DHHS”) released new compliance guidance for health care governing boards, attorneys, compliance officers and internal auditors on April 20, 2015. The guidance was developed in collaboration with the Association of Healthcare Internal Auditors, the American Health Lawyers Association, the Health Care Compliance Association, and OIG.
Previous compliance guidance from OIG emphasized the need for health care governing boards to be fully engaged in their oversight responsibility, ask questions of management regarding the adequacy and effectiveness of the organization’s compliance program, and make compliance a responsibility for all levels of management. The new guidance reiterates these principles, and provides practical suggestions for governing boards regarding oversight and review of compliance program functions. Among other things, the compliance guidance addresses the following areas:
Health care governing board members are subject to unique expectations regarding their level of engagement and involvement in the compliance obligations of their organizations. This most recent guidance suggests that OIG expects governing boards to understand the organization’s compliance obligations, work closely with management to monitor and enhance the organization’s compliance program, and to encourage compliance accountability across the organization.