In a collaborative effort designed to help health care organization boards of directors exercise their oversight responsibilities, the OIG and American Health Lawyers Association have issued a Corporate Responsibility and Corporate Compliance Resource that offers a series of "knowledgeable and appropriate" questions directors should be asking of management with respect to their organization's compliance efforts. Periodic consideration of these questions by directors, according to the Resource, will help the board establish and follow a "reasonable compliance oversight process."

Health care compliance experts view the Resource as a tool that compliance officers can use as a platform for communicating with their boards about the function of the compliance program. Panelists discussing the Resource during a teleconference sponsored by the Health Care Compliance Association note that, by opening lines of communication between boards and compliance officers, the Resource allows compliance officers to educate directors about the compliance process and to manage their expectations regarding the compliance program.

The 18 recommended questions are divided into two categories: (1) questions directed at the compliance program's structure that should help the board understand the scope of the organization's compliance program and (2) questions directed at the operation of the compliance program that should give the board some understanding of the effectiveness of the compliance program.

Like compliance programs themselves, asking the questions suggested by the Resource is not mandatory and does not provide any guarantees that problems will not arise. Following the guidance offered by the Resource, however, will demonstrate that the board has made a good faith effort to fulfill its compliance oversight responsibilities.