Managed Care Executives at Risk under the OIG Responsible Corporate Officer Doctrine
Managed care organization plan executives are facing increased personal exposure to the OIG’s administrative sanctions under the “Responsible Corporate Officer Doctrine.” In light of the serious and widespread findings from recent CMS audits of managed care plans, managed care organization board members, executives, and compliance officers need to understand their potential exposure for corporate misconduct with respect to federal health care programs or their beneficiaries.