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…
Standardizing Compliance Policy Form and Format: Tips for Compliance Officers
Compliance Officers all know that a critical part of any effective compliance program must include the development, implementation, and distribution…
2020 DOJ Compliance Program Guidelines Focuses Attention on Compliance Investigations
The 2020 Department of Justice (DOJ) Compliance Program Guidance (the Guidance) evidences an increased interest and focus on effective compliance…
Compliance Officer Challenges With Re-Opening After Lockdown
As the country moves towards returning to a fully reopened workplace, it is time to think about what should be…
2019 Health Care Fraud and Abuse Control Program Report: Summary of Results
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) established a national Health Care Fraud and Abuse Control Program…
34 Questions Boards Should Be Asking Compliance Officers
Compliance Program (CP) is an effort that begins at the Board of Directors (Board) level. Both the Department of Justice…
2020 DOJ Compliance Guidance on Employee Surveys
The U.S. Department of Justice (DOJ) 2020 Evaluation of Corporate Compliance Programs (Guidance) includes additions based on the DOJ’s experience…