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DOJ Further Revises Corporate Criminal Enforcement Policies: Focusing on Individual Accountability, Corporate Responsibility, and Additional Demands on Chief Compliance Officers

Health Law Advisor

On March 25, Assistant Attorney General Kenneth Polite announced that DOJ attorneys had been directed to consider whether a Chief Executive Officer (CEO) and/or Chief Compliance Officer (CCO) of a company should be required to certify, as part of a resolution with DOJ: the accuracy of annual reports submitted pursuant to corporate resolutions, and.

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New Safe Harbor and General Compliance Program Guidance Provides Opportunity for Buyers to Mitigate Litigation and Fraud Risk

Health Law RX

Healthcare companies should engage experienced regulatory counsel to advise about the nuances of each element as they gauge the impact that regulatory compliance may have on deal terms. But robust pre-closing due diligence is not always practicable. Conduct a thorough risk assessment of seller’s compliance program.

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Seven Elements of a Compliance Program

HIPAA Journal

The first of the seven elements of a compliance program is a suitable example of why it is important to view a compliance program holistically because it calls for the development of standards (etc.) under the direction of a compliance officer.

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What Happens if You Break HIPAA Rules?

HIPAA Journal

Whether there was knowledge that HIPAA Rules were being violated, or by exercising due diligence, it should have been clear that HIPAA Rules were being violated. These penalties are applied when the individual was aware that HIPAA Rules were being violated or should have been aware had due diligence been exercised.

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Anti-Kickback Statute Enforcement in Healthcare 

YouCompli

Tips for Compliance Officers to Manage Risk A patient undergoes surgery requiring a medical device. Routine occurrences – and a potential compliance issue if it looks like financial kickbacks are involved. You can use publicly available data to perform some initial due diligence.

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The ABC’s of Integrating AI Into Your Compliance Strategy 

YouCompli

If not already at the table, be ready to deploy the same due diligence and compliance program oversight as part of your vendor oversight initiatives. She has been the chief compliance officer (CCO) at multiple companies, including UnitedHealthcare, as well as a state assistant attorney general and a partner at a law firm.

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Mitigating Risks from Online Tracking Technologies 

YouCompli

Department of Health and Human Services’ (HHS) Office for Civil Rights (OCR) and the Federal Trade Commission (FTC) recently issued a warning regarding online tracking technologies. Compliance professionals must ensure that business associates that use tracking technologies complete a business associate agreement and comply with HIPAA Rules.