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So far Sheba Vine, JD, CPCO has created 33 blog entries.

New DOJ Guidance on Evaluating Corporate Compliance Programs

The Department of Justice’s (DOJ) Criminal Division recently released a guidance document titled “The Evaluation of Corporate Compliance Programs” for use with federal prosecutors when investigating corporations for criminal misconduct. This new document updates the 2017 version in order to align with internal processes while providing additional context to the government’s analysis of a company’s compliance

DOJ Announces Updates to the Yates Memo

On November 29, Deputy Attorney General Rod Rosenstein delivered a speech announcing changes to the Department of Justice (DOJ) 2015 policy memorandum titled 'Individual Accountability for Corporate Wrongdoing,' commonly known as the Yates Memo. The new policy revisions reflect a continued focus on individual accountability, while easing the burden for cooperation credit and providing more flexibility to DOJ attorneys in resolving matters. Key changes are summarized in this week's blog post.

Handling Requests to Access PHI under HIPAA

HIPAA provides patients with fundamental rights to access, inspect, and obtain a copy of their health information for as long as the information is maintained by the healthcare provider regardless of the date created, format of the PHI or where the PHI originated. In responding to these requests, providers should be aware of the requirements under the HIPAA Privacy Rule.

By |November 8th, 2018|HIPAA|

CMS Updates Compliance Program Training Requirements for FDRs

Establishing and maintaining a well-designed compliance program is key to preventing, detecting, and mitigating noncompliance. The seven elements of an effective compliance program outlined in the Federal Sentencing Guidelines, adopted by the Office of Inspector General (OIG),  sets the framework but there are additional requirements that need to be integrated into the compliance program in

By |October 11th, 2018|CMS|

Health Care Fraud Takedown: DOJ Holds Medical Professionals Accountable

The Department of Justice (DOJ), with assistance from the U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG) and several other law enforcement agencies, recently announced the results of its national health care fraud takedown. As the government continues to prioritize its efforts on combating health care fraud, it is prudent for

EEOC Roundup: Cases Against Healthcare Providers

The Equal Employment Opportunity Commission (EEOC) has been scrutinizing the policies of healthcare providers recently. As the federal agency responsible for enforcing federal employment discrimination laws, healthcare providers with outdated policies and/or practices may find themselves in hot water. Here are the some of the most recent cases the EEOC has initiated:   EEOC v.

Ride-Sharing Companies are your new HIPAA Business Associates

Early this month Uber introduced the launch of Uber Health, a new service that allows healthcare organizations to provide transportation for their patients. Within days, Lyft and Allscripts announced a partnership to allow healthcare providers to schedule patient rides using Allscript’s electronic health record network. The move into Non-Emergency Medical Transportation (NEMT) services is an

HIPAA Alert- Improper PHI Disclosure Leads to OCR Settlement

This week, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) announced a $100,000 settlement with Filefax, Inc., an out of business company that once provided medical records storage and disposal services. Based on an anonymous complaint, OCR’s investigation uncovered HIPAA Privacy Rule violations due to the company’s failure to

By |February 22nd, 2018|HIPAA|