The Office of Inspector General (OIG) compliance guidance recommends that organizations designate “a corporate compliance committee, charged with the responsibility of operating and monitoring the compliance program.”[4] A compliance committee is an oversight committee. The compliance committee, in contrast to a board-level compliance committee, is a management-level committee charged with oversight. It is sometimes also referred to as the corporate compliance committee, executive compliance committee, compliance oversight committee, or similar.
The compliance committee supports the compliance officer in fulfilling their responsibilities (e.g., assists in the analysis of organization’s risk areas and oversees monitoring of internal and external audits and investigations). This committee typically meets formally at least quarterly, has written agendas, takes meeting minutes, and operates under a written compliance committee charter outlining its responsibilities. The compliance department will in all likelihood be responsible for scheduling meetings, preparing the agenda, taking and distributing minutes, and coordinating follow-up. Larger organizations may also have subcommittees to the compliance committee that focus on specific areas of compliance, such as privacy, policy development, revenue cycle oversight, or similar.
The compliance officer typically serves as chair of the compliance committee, with other members coming from senior management (e.g., senior managers of relevant departments, such as billing and reimbursement, clinical, health information management, marketing, human resources, information technology, legal, operations). Compliance managers reporting to the compliance officer may also be committee members and/or attend meetings. Physicians are strong leaders in the healthcare field and should be represented on the committee as well.
The compliance committee should develop goals and objectives on an annual basis, including a written annual work plan and budget. The work plan and budget are usually reviewed and approved by the board or governing body. The compliance committee has many functions in addition to aiding and supporting the compliance officer. They include:
-
Participating in the identification and prioritization of risk;
-
Regularly reviewing and assessing compliance policies and procedures;
-
Assisting with the development of standards of conduct and policies and procedures;
-
Conducting an annual review of the compliance program;
-
Determining the appropriate strategy to promote compliance; and
-
Developing a system to solicit, evaluate, and respond to complaints and problems.
The importance and potential influence of the compliance committee cannot be overstated. Compliance committees are critical to the success of the compliance program, not only because they enable and empower the compliance officer, but also because they serve as a mechanism of communication and collaboration on compliance matters and compliance risk management across departments and divisions. Therefore, the committee needs committed individuals who will be strong, visible, and vocal advocates for the compliance program.