Join Strategic Management and SAI Global for our latest webinar on the updated DOJ guidance.
In June, the Department of Justice updated its “Evaluation of Corporate Compliance Programs.” The DOJ’s guidance is designed to assist prosecutors in evaluating whether an organization’s established compliance program was “effective at the time of the offense” and “at the time of a charging decision or resolution.” Such evaluation is used to determine the appropriate form of resolution or prosecution, monetary penalty and compliance obligations under a corporate criminal resolution. However, even organizations not under DOJ investigation can find value in this guidance document.
The DOJ has made notable changes to their original 2017 guidance. The updated guidance emphasizes that organization move beyond the “paper” structure of a compliance program to assess the program’s effectiveness. To do this, the DOJ has refocused criteria to address whether the compliance program is well designed, is applied earnestly and in good faith and works in practice.
- The evolution of the DOJ’s guidance
- Key features of the updated guidance
- Challenging factors for Compliance Officers
- Strategies for addressing the guidance
- Other important developments for compliance programs
Richard Kusserow, CEO, Strategic Management Services, previously served for 12 years in the FBI and 11 years as DHHS Inspector General. His firm, over the last 25 years, has assisted over 2000 healthcare organizations and entities with compliance advisory services, including program development, evaluations, training, risk assessments, claims analysis, and reviews required by CIAs.
Thomas Herrmann, JD, Managing Senior Consultant with Strategic Management Services, previously served as Chief of the Administrative Litigation Branch in the OIG Counsel’s Office and as a Medicare Appeals Council Judge. He has worked with many organizations in providing compliance advisory services, including serving as an Interim Compliance Officer, and acting as a Compliance Expert to the Board and an Independent Review Organization (IRO) under a CIA.