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responsibility for the management and provision of all OPO services and must

develop and oversee implementation of policies and procedures considered

necessary for the effective administration of the OPO, including fiscal operations,

the OPO’s quality assessment and performance improvement (QAPI) program, and

services furnished under contract or arrangement, including agreements for these

services. The governing body must appoint an individual to be responsible for the

day-to-day operation of the OPO.

Interpretive Guidelines §486.324(e)

Review Governing Body minutes to verify their oversight activities regarding the

development and implementation of policies, the annual budget, other fiscal concerns, the

QAPI program and services furnished under contract or arrangement.

Verify that the OPO Governing Body has appointed an individual in writing to be

responsible for the day-to-day operation of the OPO. This individual must have his/her

role defined by the Governing Body and there should be written documentation that

his/her activities are shared with or reported to the Governing Body on a routine basis. If

the Governing Body has not defined the role of this individual and there are associated

deficiencies with day to day operations of the OPO, cite a deficiency under this

regulation.

Since the Governing Body is also responsible for the OPO’s fiscal responsibilities, non-compliance with §486.303(b)(non-profit status) and §486.303 (c(assuring fiscal stability)

should be cited here.