How Important is Program Evaluation?
By now, every provider should have the infrastructure of a compliance program in place. The seven elements of an effective compliance program are well publicized and there are numerous resources available to providers for building a program. But, building a compliance program, putting policies and procedures in place, naming a compliance officer and having a […]
What Will the New Administration Bring?
We are 10 days from the start of a new administration in Washington, and it is safe to say the world of health care will feel the impact of the new administration in the not too distant future. This blog post is not intended to be political in any way, rather, is intended to shed […]
Compliance New Year’s Resolutions
As we turn the page on what can only be described as a “one of a kind” year we have a tremendous opportunity to look back at 2020 and really evaluate how the compliance program performed, and where 2021 might provide some opportunities to improve, change direction or re-tool the program. The pandemic forced providers […]
Consider the Annual Review of Compliance Policies in a New Light
As part of the annual compliance program plan of work, nearly every provider includes a review of the policies that make up the program. You may not want to admit it for your organization, but typically that annual review of policies takes about 5 minutes when the compliance officer asks the members of the compliance […]
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 […]