Compliance Forms announces the release of its Minnesota Corporate Kit and Bylaws legal form Package. Minnesota Specific Bylaws and Corporate Kit? You may find Minnesota corporate bylaws and other documents for sale on the Internet. Ours is the only comprehensive package we have found that gives you all of the documents you will need to […]
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APPOINTMENT OF COMPLIANCE OFFICER RESOLU...
Appointment of a Compliance Office is a critical element in compliance program effectiveness. Failing to appoint a compliance officer is almost an automatic indication that a compliance program is not effective. Below is an example of a compliance officer appointment resolution. The Board of Directors of _____________ (the “Provider”) as constituted on _____________, 2016, hereby […]
Internal Reporting System for Compliance...
Setting Up Your Internal Reporting Mechanism One of the primary elements in a Compliance Program is the creation of a system that permits employees and others to provide information regarding potential compliance issues without fear of retaliation. In larger organizations, multiple pathways permitting employees to make anonymous complaints should be maintained. Oftentimes providers use 24 […]
Successor Liability and Compliance Due D...
Due Diligence of Compliance Issues in Acquisitions Successor liability issues are a central factor to consider when assessing the scope of compliance due diligence. The acquiring organization must assess the degree to which it will assume liability for the past obligations of the target company. If there is no risk that past obligations for compliance […]
Skilled Nursing Facility Compliance Work...
Skilled Nursing Facility and Nursing Home Annual Work Plan The OIG’s 2017 Annual Work Plan identified a few new areas of focus relating to nursing homes and skilled nursing facilities. Nursing home compliance officers should consider these newly identified issues when developing their annual compliance work plan. Investigation of Serious Nursing Home Conditions The Work […]
Compliance Committee Charter Example
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 […]
Yates Memorandum Main Steps and Key Prio...
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 […]
Yate Memorandum Compliance Program Impac...
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 […]
False Claims Act – Lincolns Law and the
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 […]