Medical Journal Houston | Page 3

. . . . . . . . . . . . . . . . . . . . . . . . . . . . Medical . . . Journal . . . -.Houston . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Page. 3 June 2015 . . . . . . . . . . . . . . . LEGAL AFFAIRS By Mary M. Bearden and Allison Shelton, Brown & Fortunato, P.C. On April 20, 2015, the “Practical Guidance for Health Care Governing Boards on Compliance Oversight” (the “Guidance”) was published to provide an educational resource for the governing boards of health care organizations with respect to their compliance plan oversight programs. The Guidance is a result of a first-time collaborative effort by the Association of Healthcare Internal Auditors (AHIA), the American Health Lawyers Association (AHLA), the Health Care Compliance Association (HCCA), and the Office of the Inspector General (OIG) of the U.S. Department of Health and Human Practical guidance for compliance plan oversight programs Services. The cross-disciplinary publication adds to prior guidance materials published by the OIG. This joint effort reflects the importance of the complementary roles of boards, internal auditors, lawyers, and compliance officers in successful compliance oversight programs. The goal of the Guidance is to provide practical tips and ideas for boards to consider when designing compliance oversight programs. It aims to assist boards in assessing the capacity and effectiveness of compliance oversight programs in the “ever-changing regulatory landscape and operating environment” of health care today. The Guidance does not propose a “one size fits all” standard but instead provides ideas as to how organizations of different sizes and complexities may develop oversight programs that will fit an organization’s specific needs. The Guidance emphasizes the duty of a governing board to act “in good faith in the exercise of its oversight responsibility for its organization.” To assist boards in fulfilling this duty, the Guidance discusses and provides suggestions relating to four aspects of compliance programs, including: (1) roles and relationships of the organization’s audit, compliance, and legal departments; (2) mechanisms for reporting to the board; (3) approaches to identify