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Category Archives: Compliance Investigations
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
Posted in Compliance Effectiveness, Compliance Investigations
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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
Posted in Compliance Audit and Monitoring, Compliance Due Diligence, Compliance Effectiveness, Compliance Investigations, Compliance Officer, Compliance Program Elements, Corporate Compliance Programs
Tagged compliance program, compliance reporting, corporate compliance, internal reporting, reporting system
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Successor Liability and Compliance Due Diligence
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 … Continue reading
Posted in Compliance Due Diligence, Compliance Investigations, Corporate Compliance Programs, Uncategorized
Tagged Acquisition Compliance, Asset Purchase, Compliance Due Diligence, Compliance Issues, Due Diligence
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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
Posted in Compliance Audit and Monitoring, Compliance Effectiveness, Compliance Investigations, Corporate Compliance Programs, Free Compliance Forms, Health Care Compliance, Uncategorized
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False Claims Act – Lincolns Law and the Health Care Compliance Industry
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 … Continue reading
Posted in Compliance Investigations, Corporate Compliance Programs, Fraud and Abuse, Health Care Compliance, Uncategorized
Tagged False Claims Act, FCA Liability, Lincoln's Law
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Identifying Practice Outliers Using Data Mining
Data Mining Used to Identify Practice Outliers A Note From the OIG Presentation at the HCCA Compliance Institute The federal government is actively using data to identify providers who perform outlier billing. If your billing patterns reflect a pattern that … Continue reading
Posted in Compliance Investigations, Fraud and Abuse, Health Care Compliance
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