Responding to Detected Offenses and Developing Corrective Action Initiatives: Element 7
One of the most important aspects of an effective compliance program is making corrections to the systems or processes of the organization when something does go bump in the night. The Department of Justice, in its March 2023 Evaluation of Corporate Compliance Programs document specifically addresses this essential element. As stated by the DOJ “One […]
Effective Lines of Communication with the Compliance Officer and Disclosure Program: Element 6
The age-old question of “if a tree falls in the forest and no one is there, does it make a sound?” may not seem applicable to compliance but I assure you it is. If staff report a compliance issue and no one hears them, why even take the time to make the report? One of […]
In It For The Long Haul
I received a text message today from someone with whom I have been friends for over 20 years. Our friendship has had its ups and downs, and even some rocky times, but through it all we have remained friends. He is retired now and climbing mountains in Colorado while I am still working away each […]
Don’t Interrupt!
I have a confession to make. I am terrible at not interrupting people when we talk. I know it is not right, and it can even be rude, but I still find myself starting to talk before the other person is done expressing their thought far more often than I should. Maybe it is because […]
It’s the World We Live In
This week Politico published a copy of a draft opinion from the Supreme Court that was leaked by someone inside the Court. Whether the motivation of the person who leaked the document was to impact the decision of the Supreme Court, or the mid-term elections is irrelevant for the purpose of this blog post. There […]
It Has To Make Sense
This blog post is not intended to be a political statement. It is sad that I have to say that but when you even reference mask mandates, many folks assume there is a political undertone. Not at all. Yesterday, a federal judge declared the CDC mandate that masks be worn on planes, trains and busses […]
Just Ask Them!
It seems everywhere you look there is a help wanted sign. Businesses of all types are looking to hire people; the impact of the pandemic on the workforce has been staggering. Without exception, the biggest issue health care providers face now is a workforce shortage, and the resulting impact on the ability to provide quality […]
What’s Under the Snow
Spring appears to be making its way to Iowa. The snow is melting and the days are getting longer. It has been a long cold winter. It is always interesting to see what is hidden under the snow when it finally melts. Maybe it is a can that was thrown from a passing car, or […]
Showing Up Is Important
WARNING: I am going to sound like an old guy in this blog post! Over the last few months I have been struck by how common it is for people to just not show up when they have committed to be some place. Whether it is a job applicant who fails to show up for […]
They Will Never Catch Me
On February 2, 2022 the Department of Justice (DOJ) announced the conviction of a nurse practitioner from Georgia, Sherley Beaufils, for health care fraud, aggravated identity theft, and various other counts in connection with a huge telemedicine fraud scheme. In essence, her co-conspirators captured the identities of thousands of senior citizens and packaged that information […]
Break Out the Snowshoes
As a trail runner living in the upper Midwest I have a choice to make each winter. Either resort to the treadmill since everything is covered in snow, or find a way to adapt and embrace winter. When the snow flies, it is time to break out the snowshoes and run the same trails we […]
Getting the Mules on the Same Side of the Wagon
It seems our country is in a place where there are only two sides to any issue. If you don’t see an issue the way I see it, then you are wrong, and quite possibly, also evil! Whether we are talking about vaccinations, masks, right vs. left, tea vs. coffee, or chunky vs. smooth peanut […]