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The Essence of Compliance - Compliance Officer Authority and Resource Allocation

How Are Compliance Budgeting and Compliance Officer Autonomy Tied Together When Assessing Compliance Effectiveness? The Department of Justice (“DOJ”)’s compliance program evaluation identifies the need to allocate...more

Office Inspector General Launches New Compliance Resource Portal

At a recent Health Care Compliance Association (HCCA) compliance institute, the Office of Inspector General announced it had launched a new resource portal focused on compliance issues. A trip to the OIG's web site, and sure...more

Suggested Questions for the Compliance Officer

In a previous blog post, I promised to release a list of questions a Board of Directors (Board) might ask its compliance officer. This post is intended to fulfill that promise. My intent is to help Board members exercise...more

Exercising Board Oversight of the Compliance Function

The Board of Directors (Board) of an organization has oversight responsibilities over the compliance program. Board members are often unsure of the nature and scope of their responsibilities over compliance. The roll of many...more

Compliance Budgeting – Put Your Money Where Your Mouth is

You have adopted your basic compliance policies and procedures, established a reporting system and visibly rolled out your new compliance program. Your board of directors has passed a resolution decisively stating its...more

Defining the Duty of the Board of Directors over Compliance Functions

I recently posted a blog article about a document released by the Department of Justice entitled “Evaluation of Compliance Programs.” As the title of the document might suggest, the DOJ release covers a variety of issues it...more

Compliance Officer and Legal Counsel Relationships

I am often asked my opinion whether a general counsel can also serve in the role of compliance officer. At first blush, it seems the general counsel would be a perfect fit for the role because of general knowledge of...more

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