What can Jay Kogen, a writer and producer of shows such as The Simpsons, Malcolm in the Middle and Frasier, teach compliance professionals? A lot, as it turns out, as compliance training evolves to include more humor and...more
There are few businesses seen as more essential today than FedEx. Its trucks have become a lifeline for many. But just because a company can and must operate, doesn’t mean it enjoys carte blanche to do what it likes. The...more
A lot has changed with he COVID-19 pandemic, but what if your organization is under a monitorship? Have the rules changed there, too?
According to John Hanson, President of the International Association of Corporate Monitors...more
As healthcare moves increasingly from fee-for-service model to one focused on outcomes and value-based payments, the traditional fraud and abuse laws, such as the Anti-Kickback Statute and the Stark Law, pose obstacles to...more
5/28/2020
/ Anti-Kickback Statute ,
Centers for Medicare & Medicaid Services (CMS) ,
Civil Monetary Penalty ,
Compliance ,
Coronavirus/COVID-19 ,
Fee-for-Service ,
Health Care Providers ,
Healthcare Fraud ,
New Rules ,
OIG ,
Physicians ,
Policy Statement ,
Proposed Rules ,
Self-Referral ,
Stark Law ,
Telemedicine ,
Value-Based Care ,
Waivers
Companies are struggling to survive and boards are stretched beyond belief. So how do you get the governing team to focus on compliance? According to Nell Minow — dubbed the “Queen of Good Corporate Governance” by...more
Remember Brexit? It dominated the news before the pandemic. And while it may not be on the front page any longer, the clock is still ticking down to the end of the transition period on December 31, 2020.
As Andre Bywater of...more
Today’s it’s the COVID-19 Pandemic. A year from now it could be a natural disaster. But whatever the reason, even during a business interruption compliance programs still have to function effectively.
Don Griffith, Head of...more
In an interesting study, with surprising implications for compliance and ethics program, Cigna found a very lonely America. The data showed that 61% of people are lonely, feeling that they lack social support and meaningful...more
4/2/2020
/ CIGNA ,
Code of Conduct ,
Collaboration ,
Compliance ,
Coronavirus/COVID-19 ,
Employee Engagement ,
Ethics ,
Productivity ,
Remote Working ,
Social Media ,
Workplace Communication
For years In re Caremark was the definitive decision from the Delaware courts on board oversight of compliance programs. Decided in 1996, the Delaware Court of Chancery held that directors had a duty of care. However, as...more
In Part I of this two-part series, Sheryl Vacca laid out implications for health care providers struggling to respond to the COVID-19 corona virus outbreak while remaining compliant. In this episode we look at how all...more
Healthcare providers aren’t just on the front line of dealing with COVID-19 coronavirus. They are also on the front line of the compliance challenges that come with it.
As Sheryl Vacca, Senior Vice President and Chief Risk...more
As business continues to increasingly embrace the concept of risk management, where does compliance fit, particularly in the context of broader Enterprise Risk Management (ERM) frameworks? It’s a tough question that James...more
A good investigation begins well before the first allegation, according to Scott Moritz, Senior Managing Director at FTI Consulting. It begins with the creation of a proper framework for how investigations will be...more
Judith Spain is a professor of business law at Eastern Kentucky University, Compliance Collaborative Program Consultant with the Georgia Independent College Association, and, most importantly for this conversation, the author...more
Tyler Schultz, like many others, was entranced by the vision of Theranos and its charismatic founder Elizabeth Holmes. He would not remain so for long, ultimately sharing his concerns with her, his grandfather (a member of...more
Given the risks of third parties, especially in risk areas such as corruption, much emphasis is placed on thorough vetting.
But once the deal is signed and the agent or contractor is hired, the risks don’t stop there. It’s...more
Supply chains are emerging as an increasingly complex risk area for compliance. The risk includes trade compliance, vendor management issues associated with cyber/privacy, product compliance, REACH, ROHS and California...more
2/6/2020
/ Compliance ,
Corporate Social Responsibility ,
Cybersecurity ,
Data Privacy ,
Exports ,
Imports ,
Popular ,
Risk Management ,
Supply Chain ,
Trade Policy ,
Transparency ,
Vendors
For financial services firms understanding who the Ultimate Beneficial Owner (UBO) of a corporation is has become a central compliance task.
As Ellen Lafferty explains in this podcast and in the new edition of The Complete...more
1/29/2020
/ Banks ,
Beneficial Owner ,
Business Ownership ,
Compliance ,
Controlling Stockholders ,
Customer Due Diligence (CDD) ,
Exceptions ,
Financial Institutions ,
Financial Services Industry ,
Legal Entities ,
Policies and Procedures ,
Publicly-Traded Companies ,
Verification Requirements
Breaking the rules is breaking the rules no matter where it occurs. And for those of us in compliance there is much to learn from scandals of all sorts.
Chris Rose, the co-host of Intentional Talk on the MLB Network and...more
“Section 889(a)(1)(A) of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 prohibits the Federal Government from procuring or obtaining, or extending or renewing a contract to procure or obtain, ‘any...more
1/16/2020
/ China ,
Compliance ,
Exports ,
Federal Contractors ,
Foreign Policy ,
Huawei ,
Imports ,
NDAA ,
Risk Management ,
Supply Chain ,
Technology Sector ,
Telecommunications ,
US Trade Policies
Heidi Rudolph, Managing Director at Morae Global, has spent a great deal of time considering technology’s role, risks and rewards for compliance teams. She contributed an article...more
Mark Lanterman, Chief Technology Officer of Computer Forensic Services lives technology at its most terrifying, helping organizations manage the risks of the IT we all use constantly.
Recently he authored an article...more
1/7/2020
/ Business Strategies ,
Chief Compliance Officers ,
Compliance ,
Crisis Management ,
Cyber Attacks ,
Cyber Incident Reporting ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Protection ,
Data Security ,
Incident Response Plans ,
Information Technology ,
Passwords ,
Policies and Procedures ,
Public Relations ,
Risk Management ,
Risk Mitigation
Matthew Friedman is the CEO of The Mekong Club, an organization supporting the private sector in the fight against modern slavery. Previously he worked for the United Nations Inter-Agency Project on Human Trafficking and US...more
1/2/2020
/ Audits ,
Chief Compliance Officers ,
Compliance ,
Compliance Monitoring ,
Due Diligence ,
Employer Liability Issues ,
Employment Contract ,
Employment Policies ,
Forced Labor ,
Human Trafficking ,
Migrant Workers ,
Popular ,
Private Sector ,
Risk Assessment ,
Risk Mitigation ,
Slavery ,
Supply Chain ,
Vendors ,
Wage and Hour
Few things provoke more stress in the compliance and ethics community than preparing for one of the certification exams: CHC, CCEP, CCEP-I, CHRC, CHPC. Even those attending the Academies are fearful, often unduly.
For some...more
In Part 2 of this two-part podcast Michael Horowitz addresses issues that would look familiar to any compliance officer who is familiar with investigations:
- Determining who should be included in the investigations
-...more
12/10/2019
/ Chief Compliance Officers ,
Compliance ,
Confidential Information ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Information Reports ,
Inspector General ,
Internal Investigations ,
Leadership ,
White Collar Crimes ,
Witness Statements