Back to the Basics
This past weekend I had the honor of participating in my daughter’s wedding. It was a wonderful event! Weddings are a time of new beginnings, but it seems the advice everyone gives the bride and groom focuses on the basics such as communication, respect, not letting anger get the best of you, etc. The same […]
Some Perspective & Gratitude
As I am writing this blog post I have just finished “attending” the virtual Compliance Institute which is the annual conference for compliance professionals, advisors, regulators and other governmental officials. After listening and participating in presentations for the last four days I am struck by how much the field of compliance has changed when so […]
Risk Assessment – All or Nothing?
Every provider is aware of the need to conduct periodic compliance-based risk assessments, yet the process often seems overwhelming. When a risk assessment is more objective in nature, (i.e. OSHA or environmental) it is much easier to get our mind around exactly what needs to be done, what we are looking for, and how to […]
Will Congress Agree on Anything?
Every four years those of us in the world of health care wait to see what a new administration might bring our way. Where the Biden administration has many things on its wish list, two things we can expect to come down the pike actually have bipartisan support (yes, it does still happen once in […]
Think Again!
Spring is not only the season for birds to sing in the morning, days to get longer and all the plants to come alive again; it is also the season for renewing my malpractice insurance. This year, before I could obtain a quote for my renewal, I had to watch a video on fraud in […]
Wearing Stripes in a Rocking Chair
On February 23, 2021 the Department of Justice issued a press release about an administrator of a California hospice agency who was ordered to pay $2.1 million and serve 30 months in prison for his part in a $28 million Medicare fraud scheme. The administrator paid illegal kickbacks to patient recruiters for referring people to […]
Get Better Today
There is a whiteboard hanging on the wall that I see every time I walk out of my office. It has been used in the past for brainstorming, for planning, and for visually depicting the new way we do business. For several weeks it has been blank. This morning I wrote two simple sentences on […]
What Do You Do First?
It seems there is never enough time, and certainly not enough money, to do everything an organization wants to accomplish, especially when it comes to matters of compliance. Operations seems to get “first dibs” on resources because that is where the money is made. This leaves non- revenue departments, such as compliance, in a position […]
Pulling the Sides Together
There is no denying that our county is in an interesting time. While this certainly is not the darkest time in history, there is a great deal of division and mistrust in our nation, and our society right now. Right vs. left, mask vs. no mask, vaccine vs. anti-vaxxer. The issues that seem to divide […]
The Hits Just Keep Coming!
On November 6, 2020 the Office for Civil Rights issued a press release announcing the settlement of its Tenth investigation under the Right to Access Initiative. I have written about this initiative before in this blog but in light of the fact it seems like there is a new press release on the subject every […]
Dynamic and Evolving
In June 2019, when the Criminal Division of the Department of Justice, (DOJ), updated its guidance document on how prosecutors are to evaluate an organization’s compliance program, (Evaluation of Corporate Compliance Programs), one theme comes through loud and clear. Compliance policies, procedures and controls should never become stale or stagnant. Rather, the DOJ takes the […]
Dust Off the Code of Conduct and Bring It Back to Life
Most every compliance program has a document called the Code of Conduct, Code of Ethics or some other title that indicates the organization’s “commitment” to doing the right thing. Typically the document was drafted when the compliance program was first developed, and likely has not received much attention since then. It may be printed in […]