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COMPLIANCE COMMITTEE CHARTER – Introduction Example The Compliance Committee (“Committee”) is an oversight group for clinical compliance issues related to ________________ (the “System”). The Committee is advisory to both the Compliance Officer of the System and the System Compliance Officer. The Committee also assists with the Clinical Compliance Program. The term “compliance” used in this […]
General Priorities in the Yates Memorandum The Yates Memo prioritizes the manner in which Government civil and criminal law enforcement investigations are conducted. It begins by proclaiming that “One of the most effective ways to combat corporate misconduct is by seeking accountability from the individuals who perpetrated the wrongdoing . . . [accountability] it deters […]
Yates Memorandum and Progression of DOJ Pronouncement Memos The Yates Memo is the latest in a line of similar pronouncements that began in 1999 “Bringing Criminal Charges Against Corporations Thompson Memo(2003) McNulty Memo(2006) Filip Memo(2008) U.S. Attorney’s Manual (“USAM”) as the Principles of Federal Prosecution of Business Organizations(USAM § 9-28.000). The “Principles” have been revised to […]
Federal False Claims Act – Lincoln’s Law Applied to Health Care When Congress originally passed the False Claims Act (31 USC §§ 3729-3733), no one had the health care system in mind. The False Claims Act was also commonly referred to as the “Lincoln Law”. The original law was focused on unscrupulous vendors who provided […]
LIST OF COMPLIANCE-RELATED POLICIES AND PROCEDURES PROCESS POLICIES AND PROCEDURES Compliance Program Resolutions Appointment Of Compliance Officer Compliance Plan Document – General Code Of Conduct Statement Of CEO On Compliance Statement Of Board Of Directors Compliance Committee Charter Uniform Compliance Definitions Compliance Plan Elements Compliance Oversight Committee Policy Compliance Office Staff Yearly Compliance Program Review […]