You are browsing archives for
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 […]
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 […]
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 […]
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 […]