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 […]
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 […]
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 […]
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 […]