Corporate compliance and voluntary disclosure.
In any event, the decision to institute a corporate compliance program is a relatively simple one. In view of the ambiguity surrounding certain fraud and abuse provisions, and the corporate "death sentence" that may result from program exclusion, a compliance program is always sound corporate policy. To be sure, if the compliance program is administered improperly, it can actually increase the likelihood of whistleblower actions and create a body of potentially hurtful documentation. But these dangers can be minimized by structuring the program to protect the self-evaluative process through relevant privileges. The risks also pale in comparison to the exposure to criminal or exclusionary sanctions when improper conduct goes undetected by an organization.
Schiff
A B
AB
D004389:Durable Medical Equipment / Q000600:supply & distribution; D005607:Fraud / Q000331:legislation & jurisprudence*; D018574:Home Care Agencies; D007344:Insurance Claim Reporting / Q000331:legislation & jurisprudence*; D016365:Liability, Legal; D008484:Medicaid / Q000331:legislation & jurisprudence; D006278:Medicare / Q000331:legislation & jurisprudence; D016134:Organizational Policy; D010865:Pilot Projects; D012866:Skilled Nursing Facilities; D014342:Truth Disclosure; D014481:United States; D014483:United States Dept. of Health and Human Services