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Insights from the DOJ: Management Accountability for an Effective Compliance Program

The U.S. Department of Justice (DOJ) released a playbook that its healthcare fraud prosecutors will use to evaluate an entity's compliance program in February 2017 and revised in June 2020 and again in March 2023. Accordingly, management should be well versed in the factors fraud prosecutors will use to evaluate the effectiveness of an entity's compliance programs, which, in turn, influence the severity and materiality of any charging decisions.

During this session, Karin Anderson and Tynan Kugler provided an overview of these factors including industry best practices management teams can…

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