Most healthcare organizations understand the importance of having a designated compliance officer. Someone must lead compliance efforts, identify risks, and advise senior leadership and the governing body. However, the role of a compliance committee is often overlooked, especially in smaller organizations.
Unless a provider is exceedingly small, a compliance committee is a critical component of an effective compliance program. Relying solely on a compliance officer, even a very capable one, does a disservice to the organization.
Why a Compliance Committee Matters
A well-functioning compliance committee helps compliance permeate the entire organization. By bringing together leaders from different departments, the committee:
- Provides the compliance officer with insight into operational and regulatory risks across the organization.
- Encourages shared ownership of compliance responsibilities.
- Improves the implementation of new compliance requirements by incorporating diverse perspectives and expertise.
Choosing Committee Members
There is no one-size-fits-all list of compliance committee members. Every organization is structured differently, and compliance programs must be tailored accordingly. Whether you are building a committee from scratch or reevaluating an existing one, a helpful approach is to ask three foundational questions:
- What is the mission and primary responsibility of the compliance committee?
- Which areas of the organization need to be represented?
- Who has the skills and traits necessary to serve effectively on the committee?
Start with the Committee’s Mission
The best place to define the committee’s role is the Office of Inspector General’s General Compliance Program Guidance. According to the OIG, the compliance committee’s mission is to “aid and support the Compliance Officer in implementing, monitoring, and operating the compliance program.”
Key responsibilities include:
- Analyzing applicable legal and regulatory requirements.
- Developing and reviewing policies and procedures.
- Monitoring internal systems and controls.
- Assessing education and training needs.
- Overseeing disclosure and reporting mechanisms.
- Conducting the annual risk assessment.
- Developing the compliance work plan and remediation strategies.
- Evaluating the effectiveness of the compliance program.
While these responsibilities may resemble those of the compliance officer, the committee’s role is to support and operationalize compliance efforts across the organization.
Identify the Right Areas for Representation
The OIG also recommends including leaders from both operational and support functions that impact compliance, such as:
- Billing and coding
- Clinical or medical departments
- Finance
- Information technology and information management
- Internal audit
- Human resources
- Legal
- Quality and risk management
- Sales and marketing
- Operational management
A useful exercise is to review your organizational chart or reporting structure and identify leaders who oversee these functions. Titles may vary, and some departments may not exist in every organization – and that’s okay. Focus on where the function resides, not the name of the department. Include not only the top individual over the department or function, but also any additional supervisory or manager-level individuals. The goal is to have a comprehensive list of potential committee members.
Narrow the List Based on Skills and Authority
Once you’ve identified potential candidates, the next step is narrowing the list. The OIG recommends that committee members have the “authority and ability to speak for the departments they represent.”
Depending on how decisions are made within your organization, this may involve selecting senior leaders who oversee multiple departments or, in some cases, managers with specialized expertise who are more directly involved in day-to-day decision-making.
Beyond authority and expertise, consider additional traits that make for strong committee members:
- Compliance-minded and ethically focused.
- Approachable and well-respected.
- Willing to engage and follow through on action items.
- Trusted by leadership and staff.
- Able to dedicate time to committee responsibilities.
These individuals often become effective “compliance champions” within the organization.
Right-Sizing the Committee
Committee size should reflect the organization’s size and complexity. For many providers, three to seven members is appropriate, though larger or more diverse organizations may need more. If the group becomes too large, consider consolidating overlapping expertise or prioritizing members who best advance the committee’s mission. When narrowing the committee, make sure it still has key areas represented.
Moving Forward
By the end of this process, you should have a thoughtfully curated list of individuals who can meaningfully support your compliance program. From there, you can work with senior leadership to formalize the committee, establish meeting frequency, and begin setting agendas. For ideas on agenda topics and sample agendas, check out prior podcast episode 51.
Stay tuned for our next episode for tips on how to make your compliance committee more effective.
Related Episode:
Ep. 51 – Building Effective Compliance Committee Agendas
