How new sentencing guideline amendments
will impact health care senior management
Directors and high-level personnel shall be required to establish, exercise reasonable oversight and take an active leadership role for the content and operation of compliance and ethics programs.
Such governing authority will be responsible for (i) identifying and assessing areas of risk, (ii) training high-level officials (on an ongoing basis), and (iii) providing compliance officers with sufficient authority to carry out their responsibilities.
Specific individual(s) within the organization shall be assigned day-to-day operational responsibility for the compliance and ethics program and be given adequate resources to carry out the associated duties, with high-level personnel assigned ultimate responsibility for the programs effectiveness.
Small organizations (fewer than 200 employees) shall demonstrate the same degree of commitment to ethical conduct and compliance with the law as large organizations, albeit with less formality and fewer resources than would be expected of large organizations, and will be eligible for compliance program credit.