Fcpa Compliance Report

The Office of Inspector General (OIG), Department of Health and Human Resources, issued a paper entitled “Practical Guidance for Health Care Governing Boards on Compliance Oversight” (the OIG Guidance). It provides an excellent road map for thinking about how to structure a Compliance Committee for your Board and a Board’s obligations.  As an introduction, the OIG Guidance states that a Board must act in good faith around its obligations regarding compliance. This means that there must be both a corporation information and reporting system and that such reporting mechanisms provide appropriate information to a Board. It stated, “The existence of a corporate reporting system is a key compliance program element, which not only keeps the Board informed of the activities of the organization, but also enables an organization to evaluate and respond to issues of potentially illegal or otherwise inappropriate activity.” The OIG Guidance sets out four areas of Board oversight and review of a compliance function; “(1)