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DOJ Sheds Light on Evaluation of Corporate Compliance Policies

Client Alert | less than 1 min read | 02.24.17

On February 8, 2017, DOJ Fraud Section issued new guidance on the Evaluation of Corporate Compliance Programs. This guidance, discussed more fully in our blog, serves as a useful framework for compliance professionals in crafting and strengthening corporate compliance policies, corporate officers and directors who want to ensure their compliance program meets the DOJ’s expectations, and counsel to use in navigating communications and disclosures to the DOJ Fraud Section.

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Client Alert | 5 min read | 04.23.26

CMS Proposes New Payment Policy for IOPOs and HCLs

In keeping with ongoing efforts to intensify regulatory oversight of organ procurement organizations (OPOs) and curtail improper spending within federal health programs, the Centers for Medicare & Medicaid Services (CMS) recently issued a proposed rule that would, among other adjustments, align Medicare payment policies for non-renal organs to be consistent with those currently applicable to kidneys. If enacted as drafted, this latest rule could have a direct impact on the financial stability of OPOs and histocompatibility laboratories (HCL) at a time when such organizations face increasing pressure to meet CMS’s new outcome measures — or else face non-renewal or decertification later this year. ...