COSO Internal Control – Integrated Framework

An Implementation Guide for the Healthcare

2/28/2019
This guide is the result of a collaboration of the Committee of Sponsoring Organizations of the Treadway Commission (COSO), Crowe, and CommonSpirit Health. Its purpose is to introduce nonpublic healthcare organizations to the COSO 2013 revised “Internal Control – Integrated Framework” (2013 Framework) and provide implementation guidance to help strengthen and enhance their overall governance and internal control structures. The enhancement is essential as healthcare organizations have evolved from stand-alone community-based acute care hospitals to regional and national systems providing the full continuum of healthcare. Not only has size increased exponentially but so has the complexity of organizations and the environments in which they operate. Debt structure, IT infrastructure and applications, health insurance interfaces, increased provider employment, life-dependent processes, and additional state and federal regulations all have added complexity and risk for healthcare leaders to address and governance functions to oversee. Effective internal control is vital for both of these stakeholders in order to successfully weather the ever-changing healthcare environment.
COSO Internal Control – Integrated Framework
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