The Office of the Inspector General (OIG) of the U.S. Department of Health and Human Services and the American Health Lawyers Association (AHLA) released an important new educational resource for those serving on boards of health care organizations. The publication, entitled "An Integrated Approach to Corporate Compliance: A Resource for Health Care Board of Directors," is intended to provide board members with assistance in establishing and coordinating the respective roles and responsibilities of the general counsel and chief compliance officers as they relate to compliance plan management and internal reporting to the governing board.
Michael W. Peregrine of McDermott Will & Emery was a principal draftsman of the educational pamphlet, along with his colleagues Lewis Morris, the Chief Counsel of the OIG; Michael Hemsley of Catholic Health East; Jane Conard of Intermountain Healthcare and Douglas Hastings of Epstein, Becker & Green.
According to Mr. Peregrine, "The pamphlet is intended to serve as a helpful resource to the board, and to corporate counsel, in the proper exercise of the board’s compliance ‘oversight’ obligations with respect to the important related roles of the general counsel and the chief compliance officer."
AHLA will also be producing a printed version of the pamphlet for health care organizations to provide to their boards of directors and also plans to hold several related teleconferences to discuss the fiduciary duty and compliance concepts raised in the pamphlet. For additional information, please contact Michael Peregrine at 312.984.6933 or mperegrine mwe.com.