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EPA Signs "Self-audit" Agreements With Three Hospitals

Client Alert | 1 min read | 03.26.04

The New England Region of the Environmental Protection Agency has signed "self-audit" agreements with three hospitals requiring them to conduct comprehensive environmental audits of their facilities. These agreements were reached using EPA's Healthcare Compliance Initiative, under which health facilities can assess their facilities for compliance under all major environmental programs, report and correct violations, and receive relief from penalties.

The agreements are with Columbia University Medical Center, Riverside Health Care System in Westchester, New York, and Alice Hyde Medical Center, in upstate New York. If the institutions correct all violations and abide by the other terms of their individual agreements, EPA will waive "gravity-based penalties," which are normally based on the seriousness of violations.

Environmental compliance by health care institutions is an increasingly important focus of EPA enforcement. Hospitals generate a wide variety of hazardous waste, such as chemotherapy and antineoplastic chemicals, solvents, formaldehyde, photographic chemicals, radionuclides, and waste anesthetic gases, as well as solid waste. Many hospitals have been penalized for air, toxic substances and water violations. The EPA is especially interested in hospital compliance actions regarding persistent bioaccumulative toxins ("PBTs").

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Client Alert | 7 min read | 10.27.26

New Developments in DOJ Whistleblower Policies and HHS Disclosures: Key Takeaways for General Counsel, Chief Compliance Officers, and Boards

On October 20, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division announced a new whistleblower rewards initiative, the Fraud Whistleblower Incentive Program (WHIP). Assistant Attorney General Colin M. McDonald issued a directive earlier this month directing Division leadership to design and implement policies and programs that incentivize whistleblowers to bring forward credible information pertaining to fraud. The new WHIP incentive pays awards of $10,000 to $30,000 for qualifying tips at or around the time criminal charges are filed or unsealed, rather than years later at case resolution....