The Building Crew
The best architect and general contractor in the world can’t build a house alone. He/she needs good workers. Similarly, a compliance officer can’t establish or run an effective compliance program alone. He/she needs a strong compliance committee.
The OIG states the following about compliance committees:
Your compliance committee should be regularly involved in helping set up, operate, maintain and revise your compliance program, under the leadership of your compliance officer. A compliance committee that exists in name only, however, actually may do more harm than good if the provider becomes the subject of an investigation. So, each provider must determine whether creation of a committee is useful and practical (not everyone agrees that these committees are practical for small providers).
The role of the compliance committee is to assist the compliance officer in carrying out his or her duties and to assist with development, implementation, and oversight of the compliance program. Development of a compliance committee, comprised of people regularly present at the site of a provider’s operations, is particularly important when a provider appoints a compliance officer who is not routinely on-site.
Here’s some sample language you might want to use in your compliance program policy to describe the role of the compliance committee (modify this to fit your company):