CEP Magazine (June 2022) -
One of the best methods of learning about compliance and ethics programs is to review enforcement actions. And some recent actions provide very useful guidance regarding one of the most...more
CT magazine (July 2022) -
I had planned to devote this month’s column to a discussion of how organizations identify new compliance risks, avoiding the problems associated with simply reassessing the same old risks every...more
CT Magazine (June 2022) -
I recently heard the story of someone who had an interview for a job as a lab technician. And the story reminded me of an important aspect of compliance risk assessments, one that is often...more
CEP Magazine (June 2022) -
Most compliance professionals use some variation of the same model for assessing the severity of a compliance risk as part of a periodic risk assessment. Severity often considers the likelihood...more
Compliance Today (May 2022) -
Would a law that makes it illegal to mislead the chief compliance officer (CCO) help or hinder the mission of the compliance function? We may find out, albeit on a very limited scale, if one...more
Compliance Today (March 2022) -
Early in the pandemic, when employees not directly involved in patient care were sent home, much was said about the importance of making modifications to internal controls in connection...more
Environmental, social, and governance (ESG) issues have been around for many years under a variety of different names (e.g., sustainability, etc.). Until recently, ESG was often considered to be a public relations function,...more
There has been much discussion over the years about the relationship between enterprise risk management (ERM) and compliance risk management. Making the discussions more complex has been a tendency to approach risk management...more