Audits

News & Analysis as of

Recent OIG Audits of Home Health and Hospice Surveys May Signal Increased Scrutiny on Worker Qualifications

Recent audits by the Department of Health and Human Services Office of Inspector General (“OIG”) conclude that state survey agencies in a number of states and a leading national accrediting agency serving the home health and...more

The China State Administration of Taxation releases working procedures for indirect transfer rules

In early February, the China State Administration of Taxation (SAT) issued Notice 71. This Notice superseded the provisions in relation to indirect share transfers under the well-known Circular 6982 and has become the key tax...more

Plan for the Worst, Hope for the Best: Why You Must Have a HIPAA Risk Assessment

When the Office for Civil Rights (“OCR”) auditor drops by your health facility to ensure that you are complying with HIPAA, one thing is for certain: he will be asking to see your Risk Assessment. Do you have one? Is it...more

EPA Commits to Voluntary Compliance Auditing Program, Streamlines Enforcement Incentives Process

Environmental regulatory compliance auditing is a critical and central component of an effective environmental management system (EMS). To encourage companies to establish and maintain formal environmental management systems...more

ALJ Determines Taxpayer Settlement With the Internal Revenue Service Does Not Need to Be Reported to New York State

Taxpayers tend to face a difficult road when litigating tax disputes. We recently wrote about that here. It can be even more challenging, and costly, for taxpayers when they have to deal with more than one taxing authority on...more

Real Guidance (Finally) On the Compliance Oversight Role of Boards

New guidance for boards of directors on what it means to have “reasonable oversight” for the implementation and effectiveness of corporate compliance programs could signal the beginning of a global trend towards more—and more...more

Pink Flamingos and the Compliance Audit

The creator of one of the most ubiquitous symbols of mid-century Americana died earlier this week. Don Featherstone, the creator of the pink plastic lawn flamingo, the ultimate symbol of American lawn kitsch, has died. He was...more

PCAOB Launches Audit Committee “Dialogue”

As part of its audit committee outreach efforts, the Public Company Accounting Oversight Board has established a webpage called "Audit Committee Dialogue" focusing on recurrent areas of concern identified by the PCAOB over...more

Disclosing Violations to EPA in a Digital Age

Under EPA’s Audit Policy and Small Business Compliance Policy, companies that discover, promptly disclose, and expeditiously correct environmental violations may be entitled to penalty mitigation and other incentives. EPA...more

Tightening Control over Prices for Crucial Medicines

Governmental regulation of vital and essential medicines (hereinafter Essential Drugs) in the Russian Federation in the form in which it exists today has been functioning since 2010. The list of Essential Drugs (“EDL List”)...more

Health Care E-Note - June 2015

In This Issue: - Why, Again, Do You Think That Worker is an Independent Contractor? - I-9 and E-Verify Compliance Practices for Temporary Labor and Contractors - Excerpt From Why, Again, Do You Think That...more

Upcoming HIPAA Audits May Target Financial Institutions—Here’s How to Prepare

Much like a tornado watch, the conditions appear to be right for a coming storm: the upcoming Phase 2 HIPAA audits. The Department of Health and Human Services Office for Civil Rights (OCR) has begun verifying contact...more

EPA Rolls Out New eDisclosure System

On June 10 and 15, 2015, the U.S. Environmental Protection Agency (EPA) rolled out a new system for e-reporting violations being disclosed pursuant to EPA’s audit policy, eDisclosure, which is expected to go on-line as soon...more

Blog: This Year’s Conflict Minerals Filings Show Some Improvement, According To Early Review

An early review of conflict minerals filings for the 2014 reporting period shows improvement in “detail, clarity and quality,” according to this article in BNA. As reported by Elm Sustainability Partners, a conflict minerals...more

Asset Tracing in the British Virgin Islands

In this article, we will discuss some of the tools available to a party in the British Virgin Islands (BVI) to seek to recover property, or proceeds of property, which have been misappropriated. It is not surprising that in...more

Bipartisan Spotlight on Medicare Advantage Risk Adjustment Fraud Likely to Spur Audits

Potential fraud and abuse in the Medicare Advantage Program (“MA Program”) has become the focus of two senior-ranking Senators on each side of the aisle—Chuck Grassley (R-Iowa) and Claire McCaskill (D-Mo.)—and this attention...more

Deferred Compensation - Updated IRS Audit Guide

The IRS recently updated the Audit Techniques Guide that is provided to its agents with respect to deferred compensation programs, including - as the Guide specifies - salary reduction arrangements, bonus deferral plans,...more

EBSA Releases Plan Audit Quality Report, Recommends Stricter Plan Audit Standards

The DOL’s Employee Benefits Security Administration (EBSA) released a report assessing the quality of audit work performed by certified public accountants with respect to financial statement audits of retirement and welfare...more

Revised Property Transfer Tax Return Form Requests Additional Information About Hidden Buyers of New York City Real Estate

In February, the New York Times published an 8,000-word investigation into wealthy foreigners buying New York City real estate and taking advantage of U.S. laws that allow them to set up shell companies in order to obscure...more

Tax Policy Update

NUMBER OF THE WEEK: 15. The number of member nations now under increased scrutiny from European Union regulators who are aggressively hunting for violations of the EU’s “state aid” rules. The possible violations arise from...more

EPA Updates Its Audit Policy with "eDisclosure"

On June 10, 2015, the U.S. Environmental Protection Agency hosted a webinar describing a plan to modernize the implementation of its April 11, 2000 Audit Policy. The plan – called eDisclosure – attempts to provide a...more

DOL Report on Quality of Independent Plan Audits Shows that Plan Sponsors Must Continually Monitor Plan Compliance

The Employee Benefits Security Administration (EBSA) of the U.S. Department of Labor (DOL) recently released “Assessing the Quality of Employee Benefit Plan Audits,” a comprehensive report reviewing the quality of audit work...more

Tax Amnesty Hits the Midwest (and Beyond)

With many state legislatures wrapping up session within the past month or so, there has been a flurry of last-minute tax amnesty legislation passed. Nearly a half-dozen states have authorized upcoming tax amnesty periods....more

Internal Investigations: The Three C’s – Confidence. Credibility. Cost.

In this issue: - THE THREE C’S — CONFIDENCE, CREDIBILITY AND COST - WHO CONDUCTS THE INVESTIGATION? - SCOPE OF THE INVESTIGATION - MINDSET AT THE OUTSET OF AN INVESTIGATION - THE NEED FOR...more

Subcontracting Plans: How Implementing Best Practices Now Can Save You Headaches Down the Road

As a federal contractor, there are already many areas where you must track your compliance with the rules and regulations carefully. One area increasingly receiving greater scrutiny from the government is prime contractors’...more

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