Guidance for Health Care Boards

Transcript for audio podcast: A Message from
OIG for Boards of Health Care Entities From the Office of Inspector General of Department
of Health and Human Services I’m Greg Demske and on behalf of the Office
of Inspector General, I want to discuss the role of healthcare industry Boards of Directors
and Trustees in promoting compliance. Boards play a vital role in health care organizations.
They promote economy, efficiency, and effectiveness. In this regard, we share a common mission. The emergence of new payment models that reward
quality, value, and the reduction of waste, presents opportunities and risks. Going forward,
health care organizations will need to use new tools to collect and analyze data and
improve clinical effectiveness at lower costs. Last year OIG held two roundtable meetings
with representatives of entities operating under Corporate Integrity Agreements. These
CIAs result from fraud cases. We asked for feedback on compliance best practices.
The message we heard was clear. Boards have the power to enhance compliance through involvement
in oversight activities and by integrating compliance throughout the business.
You may oversee a small non-profit community provider or a large multinational corporation.
Your compliance staff may consist of one person or a broad network of professionals. Whatever
the case, you play a critical role. Here are three key roles of a health care
board member: compliance oversight, structuring your compliance program, and evaluating effectiveness
of your compliance standards and processes. First, let’s start with the Board’s role
in compliance. Serving on a health care board requires a unique skill set. Board members
should: Be engaged. The best Boards are active, raise
questions, and exercise some degree of skepticism in their oversight responsibilities. Be experienced. Is your board composed of
people with diverse areas of interest and expertise, compliance, clinical and financial
auditing expertise can be useful. Be informed. How does your organization identify,
audit, and monitor risk areas? Does your Board learn of all significant compliance issues?
Is someone responsible for keeping the Board informed? Be involved. Demonstrate a commitment to compliance.
For example, attend employee compliance training and speak to staff regarding compliance issues. And be adaptable. Healthcare delivery and
reimbursement are changing. Is your organization looking at new risk areas and developing appropriate
safeguards? Next, let’s turn to compliance program structure.
As a Board member you serve a key role in evaluating the design and implementing your
compliance program. Ask yourself these questions to determine how far-reaching and effective
your organization’s compliance structure can be.
Does your Compliance Officer report directly to the Board? Does the compliance officer
have sufficient prominence and influence within the organization?
How does your organization encourage communication between compliance staff and the rest of the
organization? Are compliance goals periodically adjusted
to account for payment reforms and new quality standards?
How does the Board encourage managers to incorporate compliance considerations into day-to-day
decision-making? Does the Board hold key employees accountable
for following compliance standards and processes? Finally, how do you know whether your organization’s
compliance program is effective? A Board should routinely review compliance
efforts across its organization to determine if its program is effective. Here are some
questions to ask to assess the effectiveness of your compliance program: What metrics are used to evaluate the company’s
compliance with laws and regulations? How were those metrics selected? How does your organization identify gaps in
quality and areas for quality improvement? Is the organization routinely conducting internal
compliance audits? Is the organization’s response to specific
problems sufficient? Does it track corrective action plans to make sure the proposed changes
are implemented? Has your Compliance Officer identified hurdles
to compliance, such as resource constraints or lack of management support?
We hope these questions will help you fulfill your important oversight responsibility as
a Board member. We look forward to continuing our discussion with industry about how we
can improve the economy, efficiency, and effectiveness of the health care system. Thank you.

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