In February 2017, the U.S. Department of Justice published guidance describing specific factors that prosecutors should consider when conducting an .. Read more investigation of a corporate entity in order to determine whether to bring criminal charges. These factors, commonly known as the “Filip Factors,” include “the existence and effectiveness of the corporation’s preexisting compliance program” and the corporation’s remedial efforts “to implement an effective corporate compliance program or to improve an existing one.” Notably, the Department of Health and Human Services, Office of Inspector General (OIG), followed-up in March 2017 with a list of questions that health care providers can use to evaluate the effectiveness of their organization's compliance program. During this session, attorneys Richard Pecore and Leonard Schneider will examine what the government expects and the steps you can take to better ensure that your health care organization is complying with applicable statutory and regulatory requirements. This webinar is scheduled for 60 minutes with a Q & A session to follow.
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