When an organization does something viewed as unethical, the public wants someone to do something about it. And that someone is likely to be “the government.” Most organizations are open to some level of government oversight. When the government comes knocking, you can expect to hand over most everything you know about the crisis. Why? Even though some of the material may be covered by legal privilege, the government will find you uncooperative if you “hide” information. Your reasoning about the crisis needs be premised on when the government finds out rather than whether the government finds out.
In an Ethics Crisis Assume the Government Will Be Involved
March 7, 2015 — Mark
ethicswhisperer.com- 4 Myths about Compliance Program Assessment February 16, 2015The first myth about compliance program assessment is that it is an optional part of an effective compliance program. The same sentence in the Sentencing Guidelines that mandates a hotline also mandates compliance program assessment. And, even if program assessment were not mandatory, it is would be incumbent on your organization to undertake assessment. Org […]Mark Pastin
- Compliance Headhunters September 21, 2014We are contacted by headhunters because we know a lot of compliance officers and we know whether they are available. However, it is extremely difficult to help these folks as they often have no idea what a compliance officer does. They are generally working from a job description written by someone in HR who also has little idea what a compliance officer doe […]Mark Pastin
- Keeping up September 8, 2014While there will continue to be new posts on longer topics on ethicswhisperer.com, I also encourage you to follow markpastin.com, which is updated more frequently and focuses on issues of the day. Of course, your comments are always welcome on any of our sites.Mark Pastin
- The Next Hot Word in Compliance July 13, 2014Hear yea! Hear yea! Hear yea! The next hot word in compliance will be UPQUALING. This, of course, is on the model of UPCODING. Healthcare reform is a gamble on the idea that incentives can be given to lower the cost of care while maintaining or improving its quality. This has been tried before with limited success under the rubrics "managed care," […]Mark Pastin
- A Big Compliance Mistake February 9, 2014Secretary of the US Department of Health and Human Services Kathleen Sibelius recently announced that health plans offered through exchanges will not be considered Federal health plans – and many breathed a huge sigh of relief. Not so easy.What the Secretary's announcement means is that plans purchased through exchanges will not be administratively unde […]Mark Pastin
- 4 Myths about Compliance Program Assessment February 16, 2015
Mark Pastin 