corporate compliance program Archives

corporate compliance program

DOJ Guidance on Evaluation of Corporate Compliance Programs: Key Takeaways

By McDermott Will & Emery, Michael W. Peregrine, Michael S. Stanek, Paul M. Thompson, Sarah E. Walters and Tony Maida on May 9, 2019
Posted In Compliance Developments, Government investigation

Boards and management should make use of recent expanded guidance from the US Department of Justice to ensure that their compliance programs are considered “effective” if and when an investigation arises. Companies should affirmatively answer three fundamental questions in evaluating a compliance program:

Is the compliance program well designed?
Is the program being implemented effectively and in good faith?
Does the compliance program work in practice?

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False Claims Act Settlement with eClinicalWorks Raises Questions for Electronic Health Record Software Vendors

By Daniel F. Gottlieb, Joan Polacheck and Tony Maida on Jun 9, 2017
Posted In Anti-Kickback Statute / Stark Law, Corporate Integrity Agreements

On May 31, 2017, the US Department of Justice announced a Settlement Agreement under which eClinicalWorks, a vendor of electronic health record software, agreed to pay $155 million and enter into a five-year Corporate Integrity Agreement to resolve allegations that it caused its customers to submit false claims for Medicare and Medicaid meaningful use payments in violation of the False Claims Act.

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