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Reporting compliance program activities to your board of directors

Jim Passey (jpassey@honorhealth.com) is Vice President, Chief Audit & Compliance Officer at HonorHealth, Scottsdale, AZ.

One of the most important stakeholder relationships a compliance officer can have is with the board of directors. The government has made it clear that the buck stops with the board when it comes to organizational compliance. As such, the board has a vested interest in knowing that the organization has an effectively operating compliance program. Receiving a routine report from the compliance officer is critical to fulfilling their fiduciary responsibilities. This relationship can also provide the compliance officer with an avenue for escalating critical issues that warrant governing board awareness and support.

The work of the board is typically divided into individual board committees for more focused discussion and attention. The efforts of those subcommittees are then reported back to the full board in their routine meetings. Compliance activities are typically reported through an audit and compliance, finance, or quality committee of the board. The actual committee assigned to receive the compliance report may be less important than making sure the compliance officer has an audience with the board to report the status and progress of the compliance program activities. Such committees typically meet quarterly, although some board committees meet monthly or bimonthly. It may be appropriate for the compliance officer to provide an in-person report to the full board of directors annually. All board members are responsible for compliance, not just those that oversee the subcommittee where compliance reports are received.

The following are suggestions on how to report compliance program activities to the board of directors.

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