2023 Board Resources

Title : Compliance: Board Compliance Program Oversight and Resolution Process Number : 4310 Version : 7

c. Reviewing any materials shared by the Chief Compliance Officer regarding compliance or regulatory issues; and d. Making reasonable inquiries into any unresolved concerns about the effectiveness of the Compliance Program. 2. The Audit Committee Chair updates the Board of Directors on compliance matters or developments, as appropriate, at each Board meeting. 3. With the assistance of the Ethics & Compliance Department, the Audit Committee creates a list that summarizes all documents and materials reviewed, as well as any additional inquiries, projects, or steps taken, in its oversight of the Compliance Program during the Reporting Period. B. Completing the Annual Resolution (Audit Committee) 1. Based upon the information shared throughout the year, the Audit Committee decides to either: a. Sign the annual resolution stating that Banner has an effective Compliance Program that meets Federal Health Care Program requirements and the obligations of the CIA; or b. Provide a written explanation of the reasons why the Audit Committee is unable to make that conclusion and the steps that must be taken to implement an effective Compliance Program. 2. The Audit Committee provides the resolution or written explanation to the Ethics & Compliance Department for inclusion in the Annual Report to the OIG. 3. The Audit Committee finalizes, with the assistance of the Ethics & Compliance Department, the list summarizing the documents, materials, additional inquiries, projects, and/or steps taken throughout the Reporting Period.

V. Procedural Documentation: A. Resolution

VI. Additional Information: A. N/A

VII. References: A. N/A

VIII. Other Related Policies/Procedures:

A. Compliance: Reporting and Investigating Potential Compliance Issues B. Compliance: Senior Management Certifications

IX. Keywords and Keyword Phrases: A. Annual Resolution B. Audit Committee C. Board of Directors D. CIA

E. Compliance Program Oversight F. Corporate Integrity Agreement G. Management Certifications H. Office of Inspector General I. OIG

X. Appendix:

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