One of the many great experiences I have been fortunate to have in my career is to meet some impressive leaders – at the Department of Justice, on Capitol Hill, and in corporations. To focus on the latter, I have met some amazing CEOs, Chief Compliance Officers, and other senior executives. To be candid, I have also met some not-so-great CEOs and senior executives. To...
Matt Stankiewicz, socio en The Volkov Law Group PC, se une nuevamente en nuestro blog con una tema de suma importancia, alivios del gobierno de Estados Unidos respecto del programa de sanciones comerciales de Venezuela por parte de la OFAC. Para mayor información: [email protected] El 18 de octubre de 2023, la Oficina de Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de los Estados...
Truth is ever to be found in simplicity, and not in the multiplicity and confusion of things. – Isaac Newton We all know the adage – Keep it Simple Stupid (“KISS”). The principle applies to all organizations and underscores an important communications requirement. The governance landscape has become more complex over the last decade with competing priorities and demands on leadership and organizations. Many...
The reach of the Anti-Kickback Statute and the False Claims Act is broad. As a result, AKS liability is a real and significant risk for healthcare companies and providers. Healthcare companies and providers have to resolve such claims because of the potential consequence of exclusion from “federal health care programs,” which is essentially a death sentence for any covered company that received federal reimbursement. In...
One of the benefits of old(er) age is perspective and experience. (As we age, we have to find the positive reasons to tout). If there is one thing (of many) the compliance profession has demonstrated, it is that compliance professionals are nimble. It comes with the territory. Building and maintaining a compliance program, requires compliance professionals to adjust their focus and prioritize resources and time...
As if corporate healthcare businesses needed an enforcement reminder, DOJ recently announced a settlement with Cigna Group for $172 million to resolve claims that Cigna exaggerated patient illnesses to extract more money from the Medicare Advantage Program. Under the Medicare Advantage (MA) Program, also known as Medicare Part C, Medicare beneficiaries have the option of obtaining their Medicare-covered benefits through private insurance plans called MA...
Matt Stankiewicz, Partner at The Volkov Law Group PC, rejoins us for an important blog posting concerning OFAC’s recent relaxation of the Venezuela Sanctions Program. Matt can be reached at [email protected]. On October 18, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) took several steps to provide Venezuela with some limited relief from its sanctions. The relief includes General Licenses authorizing...
Daniela Melendez, an Associate at The Volkov Law Group, an Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoin us for another posting on DOJ’s recent modifications to its compliance requirements. Daniela can be reached at [email protected] and Alex can be reached at [email protected]. As The Volkov Law Group previously noted in the context of a blog post authored by Michael Volkov, the U.S....
I always welcome any chance to use references to The Mandalorian series on Disney (or Ashoka for that matter) in the compliance arena. My take on the issue of electronic communications and ephemeral messaging is rooted in practical, risk-based strategies to avoid potential legal consequences that appear to be steadily growing as DOJ and courts deal with the issues. So, “This is the Way,” at...
Just to play devil’s advocate (or perhaps to push my agenda), I have conflicting views on corporate use of ephemeral messaging applications. On the one hand, I understand the importance of managing electronics communications data, prioritizing the preservation of relevant data, and reducing attendant costs from managing ever-growing amounts of electronic data. On the other hand, as a former prosecutor and now defense counsel, I...
