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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 […]
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 […]