Compliance Committees

The Audit and Compliance Committee of the Boards of Trustees

The joint Audit and Compliance Committee of the NYU Hospitals Center and NYU School of Medicine was established for the primary purpose of assisting the Boards of Trustees in overseeing compliance with legal and regulatory requirements for both the School of Medicine and the Hospitals Center. The Audit and Compliance Committee provides an open avenue of communication among financial and senior management, the internal auditing and regulatory compliance function, and the Boards of Trustees. The Audit and Compliance Committee also oversees systems of internal controls regarding finance, accounting, regulatory compliance, and business ethics that management and the Joint Boards of Trustees have established.

Compliance Oversight Committees

The Compliance Oversight Committees assist the Office of Compliance, Privacy & Internal Audit in carrying out the initiatives of the Compliance Program and in encouraging a culture of compliance throughout the Medical Center. The following Compliance Oversight Committees have been established to assist the Compliance Officer in promoting the effectiveness of the Program:

• Hospital / School of Medicine Compliance Oversight Committee
• Research Compliance Oversight Committee

These Oversight Committees, each of which is focused on a major component of the Medical Center, promote the effectiveness of the Compliance Program by performing the following leadership functions:

1. Understanding the legal/compliance requirements of the Medical Center in order to identify and assess risks to prioritize Program initiatives.
2. Recommending, developing and helping to implement policies, procedures and controls that reflect preferred practices to address and mitigate the identified risks.
3. Identifying and promoting relevant and meaningful compliance education and training.
4. Evaluating the performance of the Compliance Program including the systems for communicating, evaluating and responding to complaints and other compliance matters.
5. Helping to identify potential instances of non-compliance and potentially of waste, fraud and abuse at the Medical Center.
6. Assisting in adjudicating identified compliance issues and implementing corrective action plans.
7. Ensuring the ongoing enforcement of compliance policies and procedures and, if required, providing direction regarding disciplinary actions for repeated violations.

Operational Compliance Committees

• The Tisch/Rusk Operational Compliance Committee
• The Hospital for Joint Disease Operational Compliance Committee
• The Faculty Group Practice/School of Medicine Operational Compliance Committee

The Operational Compliance Committees are designed to act as a means of liaising between the Office of Compliance, Privacy & Internal Audit and the various departments within the institution to advance the Compliance Program. Routine interdepartmental communication will assist the Office of Compliance, Privacy & Internal Audit to evaluate the performance of the Compliance Program including the systems for identifying, evaluating and responding to compliance matters. The Operational Compliance Committees also recommend, develop and help to implement policies, procedures and controls that reflect preferred practices to address and mitigate the identified compliance risks.