There is a whiteboard hanging on the wall that I see every time I walk out of my office. It has been used in the past for brainstorming, for planning, and for visually depicting the new way we do business. For several weeks it has been blank. This morning I wrote two simple sentences on…
It seems there is never enough time, and certainly not enough money, to do everything an organization wants to accomplish, especially when it comes to matters of compliance. Operations seems to get “first dibs” on resources because that is where the money is made. This leaves non- revenue departments, such as compliance, in a position…
There is no denying that our county is in an interesting time. While this certainly is not the darkest time in history, there is a great deal of division and mistrust in our nation, and our society right now. Right vs. left, mask vs. no mask, vaccine vs. anti-vaxxer. The issues that seem to divide…
We are 10 days from the start of a new administration in Washington, and it is safe to say the world of health care will feel the impact of the new administration in the not too distant future. This blog post is not intended to be political in any way, rather, is intended to shed…
As we turn the page on what can only be described as a “one of a kind” year we have a tremendous opportunity to look back at 2020 and really evaluate how the compliance program performed, and where 2021 might provide some opportunities to improve, change direction or re-tool the program. The pandemic forced providers…
As part of the annual compliance program plan of work, nearly every provider includes a review of the policies that make up the program. You may not want to admit it for your organization, but typically that annual review of policies takes about 5 minutes when the compliance officer asks the members of the compliance…
One of the most common questions I get is whether a particular disclosure constitutes a breach that requires notification to the individual and completing a breach notification report with the Office for Civil Rights. No one likes to “fess up” that their organization has had a breach; consequently I see organizations doing some pretty interesting…
On November 6, 2020 the Office for Civil Rights issued a press release announcing the settlement of its Tenth investigation under the Right to Access Initiative. I have written about this initiative before in this blog but in light of the fact it seems like there is a new press release on the subject every…
In June 2019, when the Criminal Division of the Department of Justice, (DOJ), updated its guidance document on how prosecutors are to evaluate an organization’s compliance program, (Evaluation of Corporate Compliance Programs), one theme comes through loud and clear. Compliance policies, procedures and controls should never become stale or stagnant. Rather, the DOJ takes the…
As I write this blog post I am watching the crew working on the road in front of my office. It has been a long 5 months, yes COVID has impacted us, but we have also been unable to get into our office parking lot due to a complete reconstruction of First Street where our…