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 […]
The Sequence is Important
As I write this blog post I am watching the crew working on the road in front of my office. It has been a long 5 months, yes COVID has impacted us, but we have also been unable to get into our office parking lot due to a complete reconstruction of First Street where our […]
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 […]
“Systemic Noncompliance” – The New OCR Buzz Phrase
On September 21, 2020, the Office for Civil Rights (OCR) issued a press release announcing a $1.5 million settlement with Athens Orthopedic Clinic. The basis for the breach report that led to the settlement was the fact a journalist notified Athens Orthopedic a database of their patient records had been posted online for sale. Two […]