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DWT RELEASES COMMENTS ON OIG'S ISSUANCE
OF COMPLIANCE RESOURCE GUIDE FOR CORPORATE BOARDS
Published by the Health
Law Department
The Office of the Inspector General of the Department of Health
and Human Services (OIG), working in collaboration with the American
Health Lawyers Association, just published Corporate Responsibility
and Corporate Compliance: A Resource for Healthcare Boards of Directors
(“Board Compliance Guide”). In the wake of Enron, Sarbanes-Oxley
and various agency pronouncements, unprecedented attention is being
given to the roles and responsibilities of corporate boards. The
Board Compliance Guide acknowledges this trend and emphasizes the
unique responsibility of directors of health care organizations
due to the compliance requirements of the health care industry.
The Board Compliance Guide is designed to help corporate directors
make appropriate inquiries concerning their organizations’
corporate compliance programs. Acknowledging that the circumstances
of each organization differ, the OIG nonetheless attempts to provide
general guidance as to how directors should go about exercising
their oversight responsibilities. More specifically, the Guide 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.
Historically, many corporate boards have not exercised the type
of oversight that the Board Compliance Guide suggests. Nor has corporate
management in many organizations been prepared to respond to board
inquiries of this ilk. As the health care industry and the legal
landscape evolve, however, it appears that both boards and management
will need to be increasingly cautious in addressing these governance
issues.
If your organization is reviewing its governance structure, clarifying
the powers and operations of its board or audit committee or determining
how best to implement board oversight functions without disrupting
management or operations, Davis Wright Tremaine can assist.
The Board Compliance Guide is available online at http://oig.hhs.gov/fraud/docs/complianceguidance/040203CorpRespRsceGuide.pdf.
For Further Information, Please Contact:
Robert G. Homchick,
Seattle, (206) 628-7676, roberthomchick@dwt.com
Susan G. Duffy, Seattle,
(206) 628-7647, susanduffy@dwt.com
Brent R. Eller, Seattle,
(206) 628-7786, brenteller@dwt.com
Gerald M. Hinkley,
San Francisco, (415) 276-6530, geraldhinkley@dwt.com
Thomas E. Jeffry,
Jr., Los Angeles, (213) 633-6882, tomjeffry@dwt.com
This Health Law Advisory is a publication
of the Health Law Department of Davis Wright Tremaine LLP. Our purpose
in publishing this Advisory is to inform our clients and friends
of recent developments in health law. It is not intended, nor should
it be used, as a substitute for specific legal advice as legal counsel
may only be given in response to inquiries regarding particular
situations.
Copyright © 2003, Davis Wright
Tremaine LLP.
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