By now you know how important it is that your compliance program meets the seven recommended elements of an effective compliance program. But just because you’ve checked each of those seven boxes, doesn’t mean your compliance program is actually effective.
To illustrate that point, let’s look at the second element of an effective compliance program: “Designating a compliance officer and compliance committee.”
Many organizations simply nominate an employee (or, worse yet, assign the responsibility to someone) to serve as their organization’s compliance officer, and leave it at that. Others may go so far as to formally creating a committee. But how much time does the designated compliance officer spend on compliance-related issues? And how many times does the committee meet each year, if at all?
For best practices, the OIG has a number of responsibilities a compliance officer and the committee/governing board should be accountable for, including:
- Analyzing the organization's legal requirements and specific risk areas.
- Assessing the organization’s policies and procedures.
- Developing standards of conduct to promote compliance within the organization.
- Monitoring the compliance risks within the organization.
- Creating corrective action plans for incidents of non-compliance.
More specifically to compliance committees, the HHS OIG has stated that "Boards are expected to put forth a meaningful effort to review the adequacy of existing compliance systems and functions." In other words, regular reviews and assessments of your program is not necessarily the direct responsibility of your Chief Compliance Officer, but rather your Compliance Board, or Compliance Committee.
But even if you understand the responsibilities of a compliance committee, it doesn't mean you’re currently getting the full value out of what a truly effective compliance committee can deliver. Which is why we’ve created a new webinar, “Unlocking the Benefits of an Effective Governing Board,” where we’ll cover:
- Expectations of Your Board’s Oversight Responsibilities
- Best Practices to Maximize a Board’s Role and Responsibilities
- Lessons Learned from Boards Who Failed to Meet Oversight Responsibilities
If that’s not enough, then I should mention that just for attending, you’ll get a free 1.2 HCCA CEU certificate.
Hope to see you there!