Compliance Program
What is a Structural Policy?
A policy that creates a framework of how the compliance program will operate.
What is an effective compliance program?
An effective compliance program safeguards the organization , legal responsibility to abide by applicable laws and regulations.
What is a Compliance Program?
Compliance Program is a program about education, definition, prevention, detection, collaboration, and environment
What should be stated in the code of conduct?
Disciplinary procedures should be stated in the code of conduct and the penalty up to and including dismissel should be mentioned for serious violations.
What are top 10 reasons to Implement Program?
Strong committment to honesty, reinforce employees right & wrong, fullfills leagal duty to govt and patrons, cost effective, accurate view of employee and vendor fraud abuse, quality of care and code of conduct enhanced, prompt correction measures for misconduct, mitigate sanctions imposed by govt proactive vs reactive (voluntary compliance preferrable to waiting on govt imposed program. May protect against personal liability.
What does the code of conduct provide?
The code of conduct provides a process for proper decision making for doing the right thing.
What are Standards or code of Conduct?
The standards or code of conduct and the policies and procedures become the tools with which you can build your compliance program.
What is a substanative?
This policy defines the applicable regulations that apply to the organization and how to operate compliantly within those regulations
What are the seven basic compliance program elements?
Written standards of conduct and policies, designation of a chief compliance officer, effective education and training, Audits to monitor compliance, helpline, appropriate disciplinary mechanisms, investigation and remedi of system problems. (WOEAHDIR) Nell
A compliance program must be a committment to?
an ethical way of conducting business and a system for helping individuals do the right thing
Sentencing reform act of 1984
legislation incl the fed sentencing guide, and calculation of "cupability Scale" Worse score - upper level mgmt participation, repeat violation, govt hindered investigation, ?? and tolerance was pervaise Better score - compliance program in effect, reported promtly, organization cooperated, organization accepted responsibility
Why are compliance programs essential?
to reduce risk of probation, to reduce risk of exclusion from govt program, to reduce threat of whistle blower or qui tam law suits, to reduce imposition of govt designed programs