Search Results: conflict of interest
Developing or Revising the Code of Conduct
Key elements of any effective Compliance Program include written Compliance guidance for employees that clearly states the organization’s expectations for…
OIG Issues Updated IRO Independence and Objectivity Criteria.
The Department of Health and Human Services (HHS) Office of Inspector General (OIG) recently updated its guidance for assessing Independent…
When Moving to a Corporate Integrity Agreement, Think Ahead to Avoid Problems Later
Recent high-profile cases involving Corporate Integrity Agreements (CIAs) such as Tuomey Healthcare System and Millennium Health (formerly Millennium Labs) remind…
Independent Auditor (IA) Validation Process for Medicare Part C and D Program Audits
CMS has issued an updated memorandum mandating an Independent Auditor (IA) Validation Process for Medicare Advantage and Prescription Drug Plan…
Reflections on the “Yates Memo” and New DOJ Guidelines
This blog release is a part of a series of articles relating to the memorandum by Deputy Attorney General Sally…
CMS Establishes New Rules For Medicare Shared Savings Programs
The Centers for Medicare & Medicaid Services (CMS) recently issued a final rule addressing changes to the Medicare Shared Savings…
Frequently Asked Questions On Compliance Program Operations
Sanction Screening Must we notify employees/vendors they will be screened for exclusions? Yes. Employees, vendors, medical staff, etc. must be…
Clinical Research and the Sunshine Law: Will the Government Publish Your Name?
Currently, two regulatory events are traveling along side of each other, but not yet intersecting. That will change next year. The two regulations…
Training and Education Services
Internal Investigation Training and Education Services Strategic Management provides training on conducting an internal investigation, using some of the most…
PPACA “Sunshine” Rule Increases Transparency in Health Care
On February 1, the Centers for Medicare & Medicaid Services (CMS) announced the “Sunshine” final rule, also known as the…
Accountable Care Organizations Requirements: ACO Final Rule Summary
The Centers for Medicare & Medicaid Services (CMS) released the final rule for Accountable Care Organizations (ACOs) and the Medicare…
Sarbanes-Oxley and Corporate Governance
Sarbanes-Oxley Act Compliance Strategic Management has developed considerable experience with compliance with the Sarbanes-Oxley Act (SOX). SOX was passed in…