Get Better Today

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…

What Do You Do First?

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…

Pulling the Sides Together

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…

Do I Have to Report This as a Breach?

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…

Dynamic and Evolving

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…