Managed Care Executives at Risk under the OIG Responsible Corporate Officer Doctrine

Richard P. Kusserow | April 2011

Managed care organization plan executives are facing increased personal exposure to the OIG’s administrative sanctions under the “Responsible Corporate Officer Doctrine.”  In light of the serious and widespread findings from recent CMS audits of managed care plans, managed care organization board members, executives, and compliance officers need to understand their potential exposure for corporate misconduct with respect to federal health care programs or their beneficiaries.

About the Author

Richard P. Kusserow established Strategic Management Services, LLC, after retiring from being the DHHS Inspector General, and has assisted over 3,000 health care organizations and entities in developing, implementing and assessing compliance programs.