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Proposed Federal Guidelines For Compliance Programs Published For Comment

Client Alert | less than 1 min read | 01.07.04

By our earlier Bullet Point (Oct. 7, 2003), we advised that the US Sentencing Commission was considering substantial revisions to its guidelines for organizations and courts on what constitutes an effective compliance program. The proposed guidelines were published on 12/30/03 (68 FR 75340) for public comment, closing on 03/01/04.

Insights

Client Alert | 5 min read | 04.01.26

OPO Hospital Waiver Litigation: Trends and Takeaways

Despite facing existential challenges in several federal courts, the performance metrics established by the Centers for Medicare and Medicaid Services’ (CMS) 2020 Final Rule for organ procurement organizations (OPO) appear to be, at least for now, withstanding scrutiny in litigation proceedings.  ...