Gabe is also the former Board Chair of the Health Care Compliance Association.

Gabe Imperato

Partner, Nelson Mullins

The Hospice Board’s Key Roles In Compliance

Recently released reports on hospice by the Health and Human Services Department’s Office of the Inspector General indicate that we’re clearly in for a new era of scrutiny for hospice services. It has probably never been more important for a board to be clear on its role in ensuring that an effective compliance program is in place.

The basic responsibilities of any board, whether of a healthcare organization or not, are basically the same. But when it comes to compliance oversight, healthcare board members need to aware of the regulatory and enforcement complexities of healthcare.

  • What key documents should board members be familiar with that relate to compliance? What is a Corporate Integrity Agreement (CIA) and how can they provide guidance?
  • What key questions should a board member ask about the scope and structure of your hospice compliance program? What concerns or issues does the compliance department have about its program?
  • What should a board expect from the hospice Compliance Officer in reporting about internal inquiries of non-compliant activity?
  • What should your board know about handling external inquiries?

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