Search Results: independent
Should Compliance & Legal Be Separate? The Compliance and Legal Relationship
DOJ and OIG: Compliance should be separate and independent of legal counsel. A positive working relationship between the compliance officer…
Compliance Root Cause Analysis
DOJ Guidelines encourage seeking independent evidence of root cause identification and remediation. The Department of Justice (DOJ) has indicated that…
2021: Time for Evidencing Compliance Program Evaluation?
Key Points: Full compliance program effectiveness evaluations. Compliance program gap analysis. Employee compliance knowledge or culture surveys. The Compliance Officer,…
Compliance Investigations
The Department of Justice (DOJ) and Department of Health and Human Services Office of the Inspector General (OIG) stress the…
Documents That Support Effective Compliance Programs
Checklist of 21 Key Documents Reinforcement with key documents and metrics is key to an effective Compliance Program (CP). Any…
In 2021, Consider Meeting DOJ And OIG Guidance About Evidencing Compliance Culture
Key Points: OIG compliance guidance recommends evaluating all elements of a compliance program through employee surveys. Results of surveys early…
CMS Finalizes Changes to the Stark Law Regulations
Guest author Alexis Rose, JD provides insight and analysis on recently updated government regulations. The Centers for Medicare & Medicaid…
Investigative Records Management
Keep investigative records strictly controlled with access only on a “need to know” basis. An investigative record is any recorded…
DOJ Compliance Program Evaluations Present A Challenge For Compliance Officers
Key Points: New DOJ Compliance Program Guidance for prosecutors replaced the DOJ Compliance Expert position. Few health care organizations can…
2020 DOJ Compliance Guidance Policy Questions: Suggested Actions
There can be no doubt about the value that the Department of Justice (DOJ) places on the development, implementation, and…
Meeting the Challenges for the New DOJ Compliance Program Guidance Webinar
Join Strategic Management and SAI Global for our latest webinar on the updated DOJ guidance. In June, the Department of…
2020 DOJ Compliance Program Guidelines Focuses Attention on Compliance Investigations
The 2020 Department of Justice (DOJ) Compliance Program Guidance (the Guidance) evidences an increased interest and focus on effective compliance…