U.S. Department of Justice Issues New Guidance on Evaluation of Corporate Compliance Programs – On February 8, 2017, the Fraud Section of the U.S. Department of Justice (DOJ) published new guidance titled “Evaluation of Corporate Compliance Programs” (Compliance Guidance), which can be found at https://www.justice.gov/criminal-fraud/page/file/937501/download. In determining whether to bring charges against or negotiate plea agreements with hospitals or other organizations, federal prosecutors are required to consider “the existence and effectiveness of the corporation’s preexisting compliance program” as well as the corporation’s remedial efforts “to implement an effective corporate compliance program or to improve an existing one.”
Wellness Program – Key Concerns for Evolving Compliance – Wellness programs are an increasingly popular way for employers to encourage their workforce to pursue a healthier lifestyle. Partly because of their rising popularity, various rules have developed in recent years to ensure wellness participants are treated fairly. Two sets of rules were released by the Equal Employment Opportunity Commission (EEOC) in May of 2016 and became effective for plan years beginning on or after January 1, 2017. These rules warrant further discussion in light of key compliance issues we are seeing.
The OIG 2017 Work Plan Includes Focus on Hospitals – The U.S. Department of Health and Human Services (DHHS) Office of Inspector General has issued its Work Plan for Fiscal Year 2017. The annual Work Plan provides a summary of new, revised, and continuing reviews for DHHS programs and operations, including Medicare and Medicaid. It describes ongoing audits, evaluations, and specific legal and investigative matters. The release of the Work Plan provides an opportunity for hospitals to review their own operations and practices while comparing them to the objectives in the Work Plan in order to identify areas for compliance improvement.
Cyber Insurance: Am I Covered Now? – The cybersecurity breaches rippling through the global economy create enormous costs for the affected businesses and organizations. As a result, many companies are focusing increased attention on obtaining insurance coverage for these risks; and a recent report from PricewaterhouseCoopers estimated that the annual gross value of cyber insurance premiums will increase from around $2.5 billion in 2015 to $7.5 billion by 2020. Clearly, there is a growing need for these kinds of insurance products, and a growing demand too. However, as with any insurance product, it’s critical to know what you’re buying, and this article aims to provide some general information to inform and refine your cyber insurance purchase. Let’s start with why you need to have it.