Audits

News & Analysis as of

RAC Program to Resume Limited Reviews

On August 4, 2014, the Centers for Medicare and Medicaid Services (CMS) announced that it would allow the Recovery Audit Contractor Program (RAC) to resume a limited number of reviews in August. The program has been dormant...more

Know the Publisher’s Audit Rights: Frequency

When it comes to software license compliance, being compliant with the publisher’s licensing rules can be daunting enough. But compliance won’t stop a software audit. Scott & Scott, LLP attorney, Brian Kirkpatrick,...more

Arizona Enacts Limited Privilege For Insurance Self-Audits

Arizona has enacted a privilege applicable to voluntary compliance audits conducted by insurance companies. This “self-evaluative” privilege protects audit documents and testimony in civil and some administrative proceedings....more

Anti-Corruption Compliance Program Audits [Video]

Companies are devoting more resources to monitoring their compliance and ethics programs. Whether the audit is conducted at corporate headquarters or in the field, there are important issues which should be examined during...more

Management’s Ignorance Is Not a Defense to Copyright Infringement Claims

One of the most common reactions to an initial software audit letter is that management had no knowledge of any potential violations, that the IT personnel behavior violated corporate policy, and that management did not...more

Risk Assessments-the Cornerstone of Your Compliance Program, Part II

One of the questions that I hear most often is how does one actually perform a risk assessment? Mike Volkov has suggested a couple of different approaches in his article “Practical Suggestions for Conducting Risk...more

Transportation Employers, Can You Survive The Federal Audit “Tag Team”?

The federal Occupational Safety and Health Administration and the Federal Motor Carrier Safety Administration are tag-teaming transportation employers. They’ve signed a Memorandum of Understanding in which they agree to share...more

AHA Renews Complaints about OIG Hospital Compliance Reviews

The American Hospital Association (AHA) has renewed its complaints about OIG “hospital compliance reviews.” Last Thursday AHA Executive Vice President Rick Pollack sent a letter to Health & Human Services Secretary Burwell...more

Managing the announcement of a Department of Education Program Review

Following the initial release of the well-known and controversial 2010 GAO report concerning alleged abuses in the for-profit sector, Secretary of Education Arne Duncan issued a public letter to Senators Tom Harkin and Mike...more

Efforts to Stop Health Insurance Fraud Through Use of Contractors Under Fire

In recent reports, from June 25, 2014 and August 13, 2014, the Government Accountability Office (GAO) highlights the mixed results achieved by the federal government's increased efforts to crack down on health insurance fraud...more

The Financial Report - Volume 3, No. 16 • August 21, 2014 (Global)

Discussion and Analysis - Recently, we’ve been thinking a lot about crowds. Most sources define the term “crowds” as a large group of people gathered closely together or with something in common. The Merriam-Webster...more

Connecticut Hires Chainbridge Software LLC for Transfer Pricing Training

On July 15, 2014, the Connecticut Department of Revenue Services awarded Chainbridge Software LLC a contract worth $50,000 for on-site and remotely supported training for transfer pricing audits. Chainbridge is infamous for...more

Who Audits the Auditors?

Since the advent of Medicare in 1965, hospitals have bemoaned the cost and burden of Medicare audits. The complaints increased when CMS hired private contractors for the audits. They became deafening in 2009 with the advent...more

CMS Paying Some Providers’ Medicare EHR Incentive Payment Using Incorrect Transition Factor

We have learned that CMS has paid Medicare EHR Incentive Program Payments to some eligible hospitals using an incorrect transition factor, understating total payment. CMS personnel have informed us that they are aware of this...more

District Court Confirms Caremark Applies to Audit Committee Oversight of Internal Controls

The U.S. District Court for the Northern District of California recently granted a motion to dismiss a derivative action in which the plaintiff alleged that the directors of VeriFone Systems, Inc. breached fiduciary duties...more

Creating an Integrated Due Diligence System - Screening to Audits [Video]

Almost every FCPA enforcement action involves violations committed by third-party agents, consultants and distributors. Many companies have instituted due diligence procedures to screen third-parties, consultants and...more

BALCA Holds That, Despite Typographical Error on ETA 9089, Audit Materials Demonstrated Compliance

Before an employer may file an application under the Permanent Employment Certification (PERM) process, it must test the labor market to ensure that there are not sufficient U.S. workers who are able, willing, qualified, and...more

OFCCP Releases Proposal Requiring Contractors to Disclose Compensation Data Annually

On August 6, 2014, the Office of Federal Contract Compliance Programs (“OFCCP”) released a Notice of Proposed Rulemaking requiring federal contractors and subcontractors with 100 or more employees to submit an annual equal...more

Workplace Investigations: What You Need To Know

Employee complaints of discrimination, harassment and retaliation in the workplace have been on the rise over the past years. Employers and administrators must be ready to respond to these types of claims. In the...more

OSHA Update: Legal Privileges Can Shield Accident Reports and Safety Audits from Disclosure

Written accident and incident investigations, as well as comprehensive safety and health compliance audits, are essential components of an effective safety and health program. Unfortunately, OSHA has often pursued accident...more

BSA/SIIA Audits and Software Publisher-Initiated Audits Differ in Important Ways

Christopher Barnett, Scott & Scott, LLP attorney, shares three important differences between BSA | The Software Alliance and the Software & Information Industry Association (SIIA) audits and ones initiated by software...more

Keeping Your Due Diligence System Manageable March 31, 2014 [Video]

Companies recognize the need to develop robust due diligence procedures to review, monitor and audit third-party intermediaries, prospective acquisition and joint venture partners, and vendors/suppliers. A due diligence...more

Religious Institutions: August 2014

If the Internal Revenue Service (IRS) had a moratorium on enforcing §501(c)(3) electioneering restrictions against churches and religious organizations, the IRS states that it has been lifted incident to the settlement and...more

Avoiding Fines by Starting the I-9 Process Early. Just Not Too Early…

As we have noted in prior posts, Immigration and Customs Enforcement (“ICE”) has been aggressively pursuing I-9 inspections and imposing record fines (about $12.5 million per year) as part of its multi-year strategic plan....more

Brace Yourself: The RACs Are Back

Under the controversial program private contractors audit hospitals and other Medicare providers for fraudulent and erroneous Medicare billing. Why is it controversial? Because the auditors are paid a percentage of...more

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