We are halfway through 2024, which means: now is the perfect time to evaluate your 2024 compliance initiatives and assess how you’re doing! It’s time to give your compliance work plan a 6-month check-up....more
In November 2023, the United States Health & Human Services Officer of Inspector General (“OIG”) issued new compliance program guidance for the healthcare industry, referred to as the General Compliance Program Guidance...more
Is your organization’s culture complimenting your healthcare compliance program? Does it enhance and maximize your program’s effectiveness? Or, is your culture secretly sabotaging your compliance efforts?...more
The Office of Inspector General of the U.S. Department of Health and Human Services (the OIG) recently released an updated General Compliance Program Guidance document (GCPG). The GCPG has been anticipated since the OIG...more
The Big Picture - Many health care stakeholders have long relied on the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) guidance regarding an effective compliance program when...more
In the previous three newsletters, the authors reported about the recent challenges associated with the field moving towards a quasi-legal system. Yet, something we did not expand upon is how Title IX officers are coping with...more
On November 6, 2023, the Department of Health and Human Services Office of Inspector General (OIG) issued General Compliance Program Guidance (GCPG) via publication on its website, which can be accessed by this link. The...more
A corporate compliance program can be thought of as a magnet that brings a company’s compliance efforts together. It is an operational program, not simply a code of expected ethical behavior. An effective compliance...more
In the securities industry, regulators like to say that the compliance professionals are their “partners.” But every so often, those regulators charge one of their compliance partners with rule violations. The compliance...more
To say it’s a challenge might be an understatement: Many managers are wondering to what extent their regulators will allow them to modify compliance standards during COVID-19....more
On June 1, 2020, the U.S. Department of Justice (DOJ), Criminal Division, updated its guidance on the “Evaluation of Corporate Compliance Programs,” providing increased clarity on some of the key questions prosecutors will...more
What is CMMC? CMMC is a unified cybersecurity standard and certification program for all U.S. Department of Defense (DoD) contractors. On January 31, 2020, DoD’s Office of the Under Secretary of Defense for Acquisition &...more
Compliance officers face almost an infinite number of risks – not to be trite, but CCOs can drive themselves crazy identifying every plausible legal and compliance risk a company faces. I am exaggerating a little bit to make...more
The CFPB published a policy statement in today’s Federal Register to announce that, going forward, it is establishing a new “Compliance Aids” designation for certain Bureau guidance. The policy statement becomes applicable...more
The parallels with compliance management - Think about it: The challenges you face in managing your compliance obligations aren’t unlike bringing the family together for the holiday meal…you have to round everybody up,...more
Under Russian Data Protection Law, when collecting personal data, data operators (controllers) must ensure that recording, systematization, accumulation, storage, updating and extraction of personal data relating to Russian...more
Let’s consider a list of 20 questions to reflect the oversight role of directors. These are questions the Board should ask of both senior management and the Board itself. The questions are not intended to be an exact...more
On August 27, 2019, the Department of Labor announced that government contractor Cintas Corp. has agreed to pay nearly $650,000 to settle claims of sex and race discrimination in its Philadelphia, PA facility and end...more
The initiation of a government investigation is often a stressful and anxiety-producing event for a health care company. The Department of Justice (DOJ) is known for its aggressive investigation and prosecution of health care...more