The Need for an Effective Compliance Program
Com in the 90s, and mortgage banks and
hedge funds in the first decade of 2000.
The focus now is healthcare fraud. The
bottom line, is that the E-train (“E” for
government enforcement) has left the
Washington, DC station. The Fed has
telegraphed its departure for many
years through numerous laws, old and
new. Now, armed with the likes of
HEAT, HITECH, PPACA, the OIG and
OCR, ignorance is not a defensible position. Let’s do it right.
1Haas B. Health-care fraud is justice dept. pri-
ority, Eric Holder tells VU law students.
The Tennessean. March 17, 2012.
2Ethics Resource Center. Federal Sentencing
Guidelines. Washington, DC: Ethics
Resource Center. 2003.
3United States Sentencing Commission. 2011
FEDERAL SENTENCING GUIDELINES
MANUAL. “§8B. 2. Effective Compliance
and Ethics Program.” Available at: http://
Manual_HTML/ 8b2_1.htm. Accessed
May 18, 2012.
Jeff’s career spans more than 30 years in healthcare,
managing both inpatient and outpatient radiology
departments. He holds an associate’s degree in
radiology technology, bachelor’s degree in health
services administration, a master’s degree in
organizational psychology, and certification in
healthcare compliance (CHC). From 2009 to present,
Jeff has served as compliance officer for a multi-center,
outpatient radiology practice in Phoenix, AZ. He is
also adjunct faculty at Gate Way Community College,
Phoenix, AZ, where he teaches healthcare law and
ethics, and MRI physics and protocols. Jeff can be
contacted at firstname.lastname@example.org.