Category:The Art of Compliance
The Need for a Modified Upjohn: Internal Investigations and When to Warn
Compliance programs rely heavily on internal investigations. Yet unlike their counterparts in the in-house counsel’s office, compliance professionals rarely give notice when they are conducting such investigations. Whether compliance professionals have duty to notify individual directors, officers and employees of an internal investigation remains unclear. This lack of clarity leads to confusion with employees and officers regarding the limits of confidentiality, and the compliance officer’s duty of loyalty. A robust ethics and compliance program should therefore take a proactive stance and integrate Upjohn warnings—a standard of corporate counsel, but modified to fit the compliance function—into the internal investigation process.
Why, Why, Why, Why, Why You Should Utilize Root-Cause Analyses.
Brittany Tomkies Executive Editor Loyola University Chicago School of Law, JD 2017 Over the past decade, risk management and compliance professionals have moved away from asking “what happened” and “who did it” to asking “why” the error occurred in hopes of developing effective safeguards to prevent reoccurrence of those errors. As a result of …
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Compliance Tips to Keep Your New Year Resolution
Ryan Whitney Managing Editor Loyola University Chicago School of Law, JD 2017 With the chaotic 2016 behind us and 2017 underway, many people are working to maintain the resolution(s) they set for themselves to ensure that last year’s failures are not repeated. Sadly, more than a quarter of us have already broken these resolutions …
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How Communications Play a Key Role in the Hospital Readmissions Reduction
Fannie Fang Executive Editor Loyola University Chicago School of Law, JD 2017 CMS has reported that Medicare expenditures amount to roughly 17 billion a year on patient readmissions alone. Studies show that almost twenty percent of all patients who are admitted to a U.S. hospital makes a repeat visit within thirty days of discharge. …
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Effective Compliance Training Methods to Increase Reporting
Brittany Tomkies Executive Editor Loyola University Chicago School of Law, JD 2017 A September 2016 survey from the Society of Corporate Compliance and Ethics (SCCE) found that 83% of compliance professionals said their program prevented misconduct at least once in the last two years with 46% of respondents saying their compliance program prevented five …
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Attending the 15th Annual Compliance & Ethics Institute
Corinne Nierzwicki Production Editor Loyola University Chicago School of Law, JD 2018 The Society of Corporate Compliance and Ethics recently hosted the 15th Compliance & Ethics Institute (CEI) in Chicago, Illinois. Several Loyola faculty members and students, including myself, attended CEI. I had an excellent experience at CEI networking with attendees and learning from the …
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Compliance and The Dab
Ryan Whitney Managing Editor Loyola University School of Law, JD 2017 Dabbing has taken pop culture by storm in just the last year. Popularized by Carolina Panther’s quarterback Cam Newton, the dance move is now seen in all sorts of sports celebrations, dance adaptations, videos and promotions. It is a fad, a craze — …
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Being Held to Standards Beyond the Legal Minimum
Ryan Meade Editor-in-Chief Director of Regulatory Compliance Studies at Loyola University Chicago School of Law Here is a link to a short blog post I recently published on the SCCE’s The Compliance & Ethics Blog (“Being Held to Standards Beyond the Legal Minimum”). Organizations must go into policy-writing with eyes wide open on what exposure …
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A New Role for Compliance Programs in HHS-OIG Resolutions of Non-compliant Conduct
Ryan Meade Editor-in-Chief Director of Regulatory Compliance Studies at Loyola University Chicago School of Law A recent commentary from the U.S. Department of Health & Human Services’ Office of Inspector General (HHS-OIG) indicates it will not consider the existence of an effective compliance program as a positive factor in resolving civil non-compliance but it …
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Elemental: Internal or External Hotlines?
Ryan Meade Editor-in-Chief Director of Regulatory Compliance Studies at Loyola University Chicago School of Law Yesterday I gave a webinar on compliance program hotlines and an interesting question came in after the broadcast: “Internally staffed compliance hotlines seem like a bad idea. Doesn’t an internal hotline increase the company’s regulatory risk?” Internal hotlines could increase …
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