Category Archives: Compliance Effectiveness

Responsibility and Accountability for Compliance Program Failures

Accountability for Compliance Program Failures When a compliance program is not functioning as intended, various parties within and outside the organization may face significant risk and consequences. The following section details who may be exposed and the nature of their … Continue reading →

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APPOINTMENT OF COMPLIANCE OFFICER RESOLUTION

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 … Continue reading →

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Internal Reporting System for Compliance Concerns

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, … Continue reading →

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Skilled Nursing Facility Compliance Work Plan

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 … Continue reading →

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Yates Memorandum Main Steps and Key Priorities

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 … Continue reading →

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Compliance Policy and Procedures List of Compliance Policies

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 … Continue reading →

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