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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 […]
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 […]
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 […]
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 […]
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 […]