Health Care - Compliance Plans: Self-Defense Help for Every Officer, Manager and Board Member

March 30, 2012

In this issue:

Compliance Plans: Self-Defense Help for Every Officer, Manager and Board Member

In its fight against fraud, abuse and waste, the federal government is now requiring health care providers and suppliers that participate in federal programs to have mandatory compliance plans. In addition, managers, officers and board members are subject to the "responsible corporate officer" doctrine, which can hold individuals criminally liable for unlawful activities that occur within their health care organizations even if these individuals were unaware of unlawful activities and did not personally participate in them. Further, individual owners, managers or officers may be excluded from future federal program participation if these individuals should have known of an organization's misconduct. This will likely spell the end of a career.

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