In September, the United States Department of Justice (DOJ) updated its corporate compliance program guidance which outlines criteria to look for in determining whether an organization’s compliance program is “adequate and effective” for purposes of making, charging, and other enforcement-related decisions for DOJ prosecutors. Healthcare providers subject to federal laws, such as the False Claims Act, should have a compliance program that incorporates the DOJ guidance to maximize the effectiveness of the program and the chances for a better resolution with the DOJ of non-compliance issues.
The updated guidance can be found here. This week on the podcast, we summarize the updates and provide tips for incorporating them into your compliance programs. Check out our implementation checklist here.