Regulatory Changes to Stark Law
The Centers for Medicare and Medicaid Services (CMS) announced regulatory changes to the Physician Self-Referral Law (“Stark Law”), which prohibits…
The Importance of Exit Interviews for Compliance Program
Conducting Effective Exit Interviews for Compliance Programs Exit Interviews can be useful, but only if done right. Many organizations have…
Investigative Records Management
Keep investigative records strictly controlled with access only on a “need to know” basis. An investigative record is any recorded…
DOJ Compliance Program Evaluations Present A Challenge For Compliance Officers
Key Points: In recent years, the U.S. Department of Justice (DOJ) has issued a series of policies designed to incentivize…
Factors To Consider When Initiating An Internal Compliance Investigation
If there is a reported alleged violation of the Code of Conduct (Code), policies/procedures, laws or regulations, someone authorized to…
Why HIPAA Right of Access Should Move Up Your Organization’s HIPAA Priority List
HIPAA Privacy Officers spend a lot of time and resources on making sure workforce members are not violating the use…
Compliance Program Maturity Models
Maturity Models have been used for decades in the defense, energy, and information technology sectors. In the last few years,…
DOJ Compliance Guidance Regarding Compliance Culture
Key Points: Compliance culture repeatedly used in the DOJ Guidance. “How often and how does the company measure its culture…
An Effective Compliance Investigation Begins With A Plan
For most organizations, the need to conduct an effective compliance investigation does not arise very often, but when it does, it is…
$50 Million Anti-Kickback and Stark Law Settlement
Key Points: Physician Arrangements continue to be the highest enforcement priority for the DOJ and OIG “Whistleblower” to receive $10,000,000…
2020 DOJ Compliance Guidance Policy Questions: Suggested Actions
There can be no doubt about the value that the Department of Justice (DOJ) places on the development, implementation, and…
OIG 2019 Report on Fraud Actions and Recoveries
Key Points: $3.6 billion recovered 528 DOJ criminal convictions 747 OIG criminal actions 2,640 new exclusions In June 2020, the…