Corporate compliance

These specific, and other broader, concerns in corporate compliance with TSCA s requirements were discussed by Diamond Shamrock Corporation s D. Harlow. He described how corporate structures and procedures, including those for research and development, for companies of all sizes, have been impacted by TSCA. These impacts are generally positive in that they reflect greatly increased awareness, resources and responsiveness to questions of chemicals effects on health and environment. These benefits are seen to be in balance with their costs, expressed in the increased costs of products and services. 

Case reviews of corporate compliance with federal regulations.437... 

The large financial settlements agreed to by corporations in order to settle fraud and abuse lawsuits help illustrate one of the many incentives for health care corporations to develop corporate compliance programs. This chapter reviews several statutes that are frequently cited in fraud and abuse cases, reviews the penalties for noncompliance with federal health care reg-... 

Chapter twenty-three Corporate compliance programs and pharmacy... 

Designate a chief compliance officer and a corporate compliance committee... 

Chief compliance officers should be familiar with reimbursement issues and the laws regarding corporate compliance experience in areas such as quality assurance and risk assessment is also helpful. One of the key attributes of chief compliance officers is their independence. For this reason, the OIG recommends that the chief compliance officer be someone other than the company s general counsel or chief financial officer in order to establish a system of checks and balances. 

Under the direction of the chief compliance officer and the corporate compliance committee, each organization should develop written compliance policies that pertain to the organization s practices that may be at risk for noncompliance. The policy should clearly delineate the organization s commitment to comply with all federal and state standards, with an emphasis on preventing fraud and abuse. The compliance plan should address, at a minimum, the False Claims Act, the Anti-kickback Statutes, physician self-referral laws, and laws regarding bribery and improper gifts. Once the plan is developed, it should be reviewed and approved by the organization s board of directors. 

Corporate compliance officers and managers depend on all employees to report any potential for fraudulent practice. For example, employees might not be in a position to commit fraud direcfly, but in the course of their job, might become aware of a violahon occurring elsewhere in the organization. With their knowledge of good corporafe compliance practices, they can alert the chief compliance officer. 

The ability of the compliance officer to receive complaints from employees is vital to an effective compliance program. An effective reporting system alerts the corporate compliance committee to violations before the government discovers them or they become the subject of a qui tarn lawsuif. Any employee who recognizes fhe possible occurrence of fraud and abuse should have a means of reporting the violation without fear of repercussions. To facilitate this, written confidentiality and nonretaliation policies should be developed and distributed to all employees. To enable the... 

Radinsky G. Making sense of the federal sentencing guidelines how health care corporations can manage risk by adopting corporate compliance programs. /. Hlth. Law 1997 30 113. 

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