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Healthcare boards require annual compliance education by Betsy Wade

 

Your healthcare organization’s stakeholders aren’t the only individuals who need annual compliance training; your board members do, too. 

Annual compliance education for board members should focus on their corporate governance and fiduciary obligations, including the duties of care, loyalty, and obedience. 

The duty of care explains how board members should proactively participate in meetings. The duty of loyalty requires board members to act in the best interests of the organization — not their own. And the duty of obedience stipulates that board members act consistently with corporate bylaws and follow all applicable laws and regulations. 

In addition to its fiduciary obligations, the U.S. Sentencing Commission Guidelines state an entity’s “governing authority shall be knowledgeable about the content and operation of the compliance and ethics program and shall exercise reasonable oversight with respect to the implementation and effectiveness of the compliance and ethics program.”

The U.S. Department of Health and Human Services Office of Inspector General’s (OIG) General Compliance Program Guidance outlines additional information the board should be educated on, relevant to the compliance program, such as:

  • Oversight of the compliance officer and the compliance committee. 
  • Ensuring the compliance officer is independent and has enough resources to implement and maintain a compliance program for an organization of its size and complexity.
  • Ensuring the compliance officer is part of the senior team and can inform the board of risks without fear of repercussions. 
  • Meeting with the compliance officer regularly, and no less than quarterly.
  • Reserving time at each meeting for an executive session with the compliance officer without non-board members present. 


Boards can further boost their expertise by attending compliance education outside of the organization. Organizations like HCCA offer compliance training designed for board audiences at national and regional conferences. 

Adding an independent board member with experience in regulatory, compliance, or legal can also expand the board’s expertise. And hiring a compliance expert or compliance effectiveness expert to consult with regularly can provide board members with additional knowledge. 

For more information, check out: 

  • OIG, “HEAT Provider Compliance Training,” video guidance for healthcare boards, accessed December 2, 2025, https://www.oig. hhs.gov/newsroom/video/2011/ heat_modules.asp#hcb-guidance.
  • U.S. Sent’g Commission, Guidelines Manual, (U.S. Sent’g Comm’n 2021),, https://www.ussc.gov/sites/default/ files/pdf/guidelines-manual/2021/ GLMFull.pdf. 
  • OIG, Association of Healthcare Internal Auditors, American Health Lawyers Association, and the Health Care Compliance Association, Practical Guidance for Health Care Governing Boards on Compliance Oversight, April 20, 2015, https:// www.oig.hhs.gov/compliance/ compliance-guidance/docs/ Practical-Guidance-for-Health-Care­ Boards-on-Compliance-Oversight.pdf.
  • OIG, “A Toolkit for Health Care Boards,” accessed December 2, 2025,
  • https://www.oig.hhs.gov/newsroom/ video/2011/toolkit-handout.pdf. 

   

 

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