DHHS Publishes Compliance Guidance for Healthcare Corporate Boards
In the wake of highly publicized corporate scandals, increasing attention is being given to the responsibilities of corporate boards. In a unique collaboration, the Office of the Inspector General ("OIG") of the Department of Health and Human Services ("DHHS") and the American Health Lawyers Association have published “Corporate Responsibility & Corporate Compliance: A Resource for Healthcare Boards of Directors” ("Guidance"). This educational resource acknowledges that directors of health care organizations have responsibilities related to corporate compliance requirements that are unique to the health care industry.
Today’s health care industry operates in a heavily regulated environment. Over the last decade, the risks associated with non-compliance have grown dramatically. Incurring civil penalties, criminal charges or being excluded from participation in federal health care programs can jeopardize the viability of an organization. For this reason, the number of corporations adopting fraud and abuse compliance programs has grown dramatically. A recent survey by the Health Care Compliance Association, found that in just three years, the number of health care organizations with active compliance programs has grown from 55 percent in 1999 to 87 percent in 2002.
The Guidance is designed to help directors exercise their oversight responsibilities by making appropriate inquiries concerning their organization’s corporate compliance programs. The Guidance includes a list of suggested questions for directors to pose to management relating both to the structure of the organization’s compliance program and its operations.
The Guidance is available online at:
www.oig.hhs.gov/fraud/docs/complianceguidance/040203CorpRespRsceGuide.pdf
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