On Monday, April 20, the Inspector General of the Department of Health and Human Services (HHS OIG) announced a new joint guidance for hospital governing boards to assist them in carrying out their compliance plan oversight obligations: Practical Guidance for Health Care Governing Boards on Compliance Oversight (Guidance). The Guidance discusses the organizations’ obligations to comply with various federal and state regulations, as well as how to identify and avoid kickbacks, overbilling, and other malfeasance that can lead to civil and criminal punishment.
Given heightened industry and professional interest in governance and transparency issues, this document seeks to provide practical tips for Boards as they work to effectuate their oversight role of their organizations’ compliance with State and Federal laws that regulate the health care industry. Specifically, this document addresses issues relating to a Board’s oversight and review of compliance program functions, including the: (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 objectives.
(See page 1 Practical Guidance for Health Care Governing Boards on Compliance Oversight.)
This guidance is unique due to its collaboration amongst four groups: HHS OIG, the Association of Healthcare Internal Auditors, the American Health Lawyers Association, and the Health Care Compliance Association. The guidance will help governing boards, as well as the internal auditors, lawyers and compliance officers that report to those boards.
The HHS OIG Media Communications recently released a press release stating the following about the guidance, “This new educational resource provides practical ideas that boards may consider implementing in their organizations. The guidance includes processes for identifying risks, tools for improving adherence to program objectives, and effective reporting tools for board meetings.”
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