Compliance Perspectives

Odell and Kortney sit down over a cup of coffee at SCCE’s European Compliance & Ethics Institute in Prague to discuss the last 30 years of compliance, including: * The biggest compliance challenges they faced 30 years ago; * How to get over the challenge of compliance as a “cost center”; * Building a defensible case for the company to prevent or negate criminal intent allegations; * Persuading your business partners (the ones creating the risk) that they are ultimately responsible for the risk; * The forward progress in compliance in Europe: * Why are things evolving so quickly; * Focus on compliance in the anti-corruption and bribery realms; * The post-Snowden impact on privacy; * Danger areas for current compliance professionals; * When a Compliance Officer knows about and is complicit in criminal activities; * Why Compliance professionals should reach outside their comfort zones; and * Where compliance is heading in the next 30 years. Odell Guyton is a Certified Compliance and Ethics Professional and the Co-Founder and a Member of the Board of Directors of the world’s largest compliance organization, the Society of Corporate Compliance and Ethics.  He is a recognized industry leader in designing, implementing and managing effective corporate compliance programs for multi-national organizations. Mr. Guyton is the former Corporate Vice President, Head of Global Compliance for Jabil Circuit, Inc., and the former Assistant General Counsel, Anti-trust Compliance Officer and Director of Compliance for Microsoft Corporation. Mr. Guyton has served as an Assistant United States Attorney and as a Deputy District Attorney. He has been named as one of the “100 Most Influential Persons in Business Ethics” and “Attorneys Who Matter.” Mr. Guyton is a frequent lecturer on the implementation of anti-corruption/anti-bribery compliance measures focused on U.S. Foreign Corrupt Practices (FCPA) and the U.K. Anti-Bribery Act and the administration of 3rd party due diligence compliance. In addition, he participates on several United Nations workshops and holds the Martindale-Hubbell “AV” (Preeminent) Highest Peer Review Rating. He received his Juris Doctor degree from the American University, Washington College of Law and earned his Bachelor of Arts degree from Moravian College, Bethlehem, Pennsylvania.

Regina, Gary and Kortney sit down at HCCA’s Compliance Institute to discuss the impact of compliance on Drug Diversion, including: * What drug diversion is and why it is an important compliance issue; * Statistics that show how harmful drug diversion can be, including: * In 2015, Medicare spent $4 billion on commonly abused opiods; * A large percentage of pharmacists, nurses, and MDs self-disclose drug abuse issues; * 1 in 3 Medicare beneficiaries is receiving some type of opiod; * Why Compliance is in a unique position to break the silos; * How compliance can address issues in real time, where criminal investigations can’t; * Compliance officers can engage in conversations with employees to gain insight into what is happening in the facility; * The importance of reporting the illegal prescribing of opiods; * Is compliance training enough? * We need to concentrate on preventing diversion – once it happens it’s too late; and * How compliance can proactively help clinicians avoid diversion issues (using data). Regina Gurvich has worked in health care in New York City for over 15 years, specializing in compliance and regulatory affairs. She currently heads the compliance effort for AdvantageCare Physicians, a newly-created 450-physician and 3,500-employee private medical practice in New York City. Prior to promotion, she served as a CCO of Manhattan’s Physician Group, one of the 4 legacy practices comprising AdvantageCare Physicians. Prior to joining Manhattan’s Physician Group, she served as Chief Compliance Officer of University Physician Associates, a faculty practice plan of University of Medicine and Dentistry New Jersey in Newark, where she was responsible for the compliance education and audit program for 700 New Jersey Medical School faculty physicians. She also served as a Director of Compliance and Special Investigations Unit for Health Plus PHSP Inc., one of the largest Medicaid managed healthcare plans in New York City. Regina served on an Advisory Task Force for New York Office of Medicaid Inspector General Compliance Guidance for Managed Care Organizations. She is a frequent speaker at the industry forums with Health Care Compliance Association and Healthcare Financial Management Association and is a member of the editorial review board of HCCA Auditing & Monitoring Tools publication. Gary Cantrell is the Deputy Inspector General for Investigations and leads the Office of Investigations (OI) within the Department of Health and Human Services (HHS), Office of Inspector General (OIG). Since 2012, he has been overseeing the operations and resources of OI, an office with more than 600 employees including investigators, analysts, forensic examiners, and administrative staff. Under Mr. Cantrell’s leadership, OI has had record accomplishments with nearly 6,800 criminal and civil actions, more than 18,000 exclusions, and over $21 billion in investigative receivables. Through his engagement with the Health Care Fraud Prevention and Enforcement Action Team (HEAT), Mr. Cantrell coordinates with the Department of Justice and State law enforcement agencies to prevent fraud in the Medicare and Medicaid programs. In June 2016, this partnership oversaw the largest national health care fraud takedown in history, resulting in charges against 301 individuals for approximately $900 million in false billing

HHS Office for Civil Rights Senior Advisor for HIPAA Compliance and Enforcement, Iliana Peters, joins Kortney at HCCA’s Compliance Institute to give our listeners an OCR Enforcement Update, including: * Recent cases and settlements reflecting ongoing compliance and enforcement issues; * The importance of enterprise-wide risk analysis and safeguards required by the Security Rule; * Privacy and disclosure issues (and tips for getting employees to understand who, what, where, and when they may disclose); * Breach trends and issues with cybersecurity; * The scary business of removable media like laptops, thumb drives, and cell phones (if it can walk away, it will); * Changes to provisions in the HITECH Act regarding sharing of recoveries; * Guidance on PMI research programs and the “All of US” campaign (How do you protect information when HIPAA doesn’t cover it?) ; and * Advice for dealing with Certified EHR Technology. For a copy of Iliana’s Compliance Institute OCR Update Slides, click here. OCR’s HIPAA Guidance Materials, click here. Iliana L. Peters, J.D., LL.M., is the Senior Advisor for HIPAA Compliance and Enforcement at the HHS Office for Civil Rights. In this role, Ms. Peters is the national lead for OCR enforcement of the HIPAA Rules, and works closely with OCR’s ten regional offices to promote compliance with the HIPAA Rules. Additionally, she supports many other OCR policy and outreach initiatives, including rulemakings, compliance initiatives with other federal agencies, and training, including of the State Attorneys General. Prior to joining the Health Information Privacy Division headquartered in D.C., Ms. Peters worked as an Equal Opportunity Specialist and compliance investigator in Region VI in Dallas, Texas. Ms. Peters received her Law Degree from Duke University’s School of Law and her Masters of Law in Health Care Law from the University of Houston’s, Law Center’s, Health Law and Policy Institute. Prior to joining OCR, she worked in private practice in San Antonio, Texas.

Laura Ellis and Donna Thiel take some time out at HCCA’s Compliance Institute to sit down with Kortney and discuss what makes for a successful CIA, including: * Building a relationship with Laura as the OIG Monitor and Donna as the Chief Compliance Officer; * The refreshing view the OIG takes on Corporate Integrity Agreements; * The importance of honest communication with and between the CCO and Monitor; * Why Compliance Officers should try to be involved in the negotiations before the CIA is even signed; * How to get upper management to understand the goals of the CIA and the OIG (they want to help you, not hurt you); * How setting five-year goals makes everything go more smoothly; * The most common challenges compliance officers face under Corporate Integrity Agreements – from Laura and Donna’s perspectives; and * The positive results of working hard under a CIA. For a copy of Laura & Donna’s slides from their Compliance Institute presentation “Making the Most of a CIA”, click here. Laura Ellis is a senior counsel in the Office of Counsel to the Inspector General at the Department of Health and Human Services. Ms. Ellis works with the Department of Justice on false claims act cases, monitors corporate integrity agreements, and specializes in exclusion appeals. Prior to joining the Office of Counsel to the Inspector, Ms. Ellis served for five years as an attorney in the Department’s Office of General Counsel, CMS Division. At the Office of General Counsel, Ms. Ellis worked primarily on Medicare reimbursement litigation. Ms. Ellis graduated from the University of Pennsylvania Law School in 1993 and worked at a legal aid office for four and a half years before joining HHS. Donna Thiel is the Director for the Compliance Integrity team, a consulting division of ProviderTrust. Donna works with compliance officers across the country to help reduce the stress and anxiety of this very difficult role. Donna assists Compliance Officers by providing consulting services in areas such as strengthening compliance programs, managing government investigations, implementing and managing a Corporate Integrity Agreement and preparing for the various regulatory changes that impact healthcare providers. Donna has been in the post-acute healthcare setting for over 30 years.

Taped live at SCCE’s 5th Annual European Compliance & Ethics Institute, Tom & Roy get a chance to reunite and catch up on some recent compliance happenings, including: * The DOJ’s recent guidance on compliance programs and why Roy thinks it’s like finding the dead sea scrolls; * Tom compares Roy’s to Plato (and the parable of the cave); * HCCA and the OIG work together to produce a joint document for compliance programs; * Even thought it’s great – the document in it’s entirety will apply to no one company, but will help everyone; * Measuring the effectiveness of your compliance program three ways; * Why Roy thinks the CO shouldn’t chair the compliance committee – but maybe the general counsel should; * Who Tom things should chair the compliance committee; * Why you should prove your point 5 different ways instead of just 1; * Brexit: Keep Calm and Do Compliance; and * How Compliance transcends politics. Click here for the joint OIG-HCCA “Measuring Compliance Program Effectiveness: A Resource Guide” Thomas Fox has practiced law in Houston for 30 years. He is now the Compliance Ambassador for the Red Flag Group.Tom is the author of the award winning FCPA Compliance and Ethics Blog and the international best-selling book “Lessons Learned on Compliance and Ethics”. His seminal book, “Doing Compliance: Design, Create, and Implement an Effective Anti-Corruption Compliance Program” is widely viewed as one of the top one-volume books on the nuts and bolts of compliance. He is one of the top leaders in social media in compliance, blogging, podcasting, writing and speaking across the globe on anti-corruption and anti-bribery compliance programs. Roy Snell (roy.snell@corporatecompliance.org) is the CEO of the Health Care Compliance Association (HCCA) and the Society of Corporate Compliance and Ethics (SCCE), which together now total more than 17,000 members. Roy was a co-founder and the organization’s first President. He has developed numerous partnerships with government, industry, and other professional associations, and he has facilitated collaboration between the compliance/ethics profession and the enforcement community. Roy has a Masters degree in Health and Human Services Administration. Through his work with the two associations, he has overseen the development of compliance and ethics books, manuals, videos, conferences and audio conferences. He has been a regular speaker in the compliance profession for more than ten years and has spoken internationally for the United Nations on compliance and ethics. He is a Certified Compliance and Ethics Professional (CCEP)®. Roy writes more than 25 compliance articles annually and has written for several international publications, including European CEO and The European Business Review. Roy is the co-editor of the Health Care Compliance Professional’s Manual and serves as editor, co-editor and advisory board member of several other books, magazines and newsletters. He has served as a source for many media reports, including national publications such as the Wall Street Journal, Forbes Magazine and Business Week. He has been quoted in international publications such as Financial Times and Ethical Corporation.

Jonathan and Kortney sit down at SCCE’s European Compliance & Ethics Institute to discuss the impact Brexit will have on compliance programs, including; * Not getting bogged down by the prevailing uncertainty surrounding Brexit; * Why we should focus on the certainties like GDPR, Data Transfer Deals, and the UK Bribery Act; * The prediction that the EU may be kinder during Brexit than the UK initially feared; * How and why to apply lessons learned from EU accession countries; * The article 50 filings and the 2-year plan going forward; * Planning for business agreements that will survive Brexit; * EU/UK/Brexit attorney-client privilege issues; * The loss of the common-law voice in the European community (and who will speak up for the UK and US now); * Potential threats to US corporations; * Why planning is always the best idea – and why your business should be putting Brexit on the agenda; and * Great resources to help you work through the compliance challenges during the Brexit process. To read Jonathan’s original blog post on Brexit, click here. Jonathan Armstrong is a compliance and technology lawyer and partner at Cordery,  helping multinational clients with risk and compliance across Europe. Recent projects include lots of GDPR & data transfer, UK Bribery Act 2010, internal investigations, security breach, helping retailers move sales online or enter new markets, launch of innovative new products and services, ethics & compliance code implementation, emerging technology, corporate governance & online reputation. Clients include Fortune 250 organisations as well as household names in manufacturing and financial services in Europe. A regular broadcaster, Jonathan has also written articles on technology and compliance related topics, and is a Fellow of The Chartered Institute of Marketing (FCIM) and Vice-Chair of the New York State Bar Association International Section. Jonathan has spoken at conferences in the US, China, Brazil, Canada, Vietnam, Singapore, Dubai & across Europe. Specialties: Qualified as a solicitor in the UK in 1991; specialised in technology, risk & governance since 1996. The 2016 Legal Experts Report again featured Jonathan as one of the UK’s leading experts in the field. Jonathan’s practice is international. One of the 3 co-authors of the LexisNexis definitive work on technology law ‘Managing Risk: Technology & Communications’.

Frank and Kortney sit down at HCCA’s Compliance Institute to discuss risk and what it means to have F.E.A.R., including; * Why risk needs to be in your DNA; * The 3 elements of risk; * The 3 dimensions of risk; * The meaning of F.E.A.R. (and why it’s not scary); * How and why to say KNOW instead of NO; * Risk mitigation strategies; * Assessing your Board’s risk appetite; * Helping front-line staff understand their risks; * Reasons to walk the hall; and * Why you always see Frank smiling. Frank Ruelas is a Facility Compliance Professional for St. Joseph’s Hospital and Medical Center located in Phoenix, Arizona within the Dignity Health system. His ongoing duties include working with members of the workforce, at all levels, to help identify how to maximize the opportunities to promote compliance within the organization. Frank’s interest in New Employee Orientation stems from his position that compliance is everyone’s responsibility. A self-described life-long learner of Compliance and some of the specialty areas within it such as HIPAA and the CMS Conditions of Participation, Frank is always searching for ways through collaborating with others to identify effective ways to manage compliance the organization’s compliance program. If you find that the name or voice sound familiar, it may be because Frank has participated in previous HCCA webinars and has presented at several HCCA Compliance Institutes, as well as having a monthly column in HCCA’s member magazine, Compliance Today. You can find Frank on LinkedIn here. In addition, you can network with Frank and other healthcare compliance professionals on HCCAnet – HCCA’s dedicated social media site for compliance pros. Visit HCCAnet here. Below is Frank’s presentation from the 2017 Compliance Institute: You can download a PDF of these slides from HCCA’s website.

  By Adam Turteltaub adam.turteltaub@corporatecompliance.org Editor’s Note:  Chris Bohjalian’s latest novel The Flight Attendant just made the NY Times Bestseller List.  We are sharing his October 2017 podcast with us again in case you missed it.  We hope you enjoy his perspective on ethics in fiction and in real life. One of the stranger things in compliance and ethics is that if you sit people down for compliance and ethics training, they tend to issue at a minimum a silent groan.  Yet, those same people will happily sit down with a novel where the protagonist is wrestling between right and wrong. There is much that can be learned from the ability of novels, as well as TV and movies, to help us learn about right and wrong.  This media can also teach us a great deal about how we react when we see others behaving badly. To explore this issue I sat down for a podcast with Chris Bohjalian, whose book Midwives was selected for Oprah’s Book Club.  His novel The Sleepwalker was just released in paperback, and in March 2018 (not 2019 like I said in the interview) his newest book, The Flight Attendant, arrives. Listen in to the podcast as we discuss: * The human fascination with moral ambiguity and people who do the wrong thing * Our fascination with how good people can do the wrong thing and the recognition that we easily could make moral mistakes * The influence of television, movies and books on whom we see as good and evil * Our discomfort with people who are “too good” * What Tony Soprano and Don Draper have done to our perception of what people will tolerate * The notion that “it’s only business, nothing personal” and the problems that may create * The cover up being worse than the crime and the value of stopping problems when they are small * Why people welcome ethical dilemmas, and right and wrong in novels, films and TV, but not when it is a part of training

Art and Kortney sit down in Minneapolis to discuss some best practices for compliance and ethics training programs, including; * Why we need to train employees in the first place (hint: think Sentencing Guidelines); * How often you need to be training; * Training the right people on the right things at the right time; * The benefits of in-person training; * How to evaluate your training program; * Keys to measuring retention and understanding; * Overcoming training challenges; * Ideas to make training fun (This…is…Jeopardy!); * Legal implications of your training; and * How to keep your training program out of hot water. Art Weiss is Chief Compliance and Ethics Officer for TAMKO Building Products, Inc. in Joplin, Missouri. He designed and administers TAMKO’s first Compliance and Ethics Program and its first Code of Ethics. He personally delivers ‘live’ Prevention of Harassment and Ethics training to all TAMKO employees. He also teaches Global Compliance as an adjunct Professor of Law for Loyola University of Chicago. He serves on the Board of the Society of Corporate Compliance and Ethics/ Health Care Compliance Association (SCCE/HCCA) and on the Compliance Certification Board. He is a faculty member of SCCE’s Compliance and Ethics Academies, and participates on the examination writing committees for the CCEP (Certified Compliance and Ethics Professional), CCEP-F (Fellow) and CCEP-I (International) certifications. Prior to joining TAMKO, Art served as a Senior Counsel in the Law Department of Sears, Roebuck and Co. in Chicago, on matters of Compliance, Trade Regulation, Marketing, Retail Operations and Loss Prevention. His responsibilities included review of marketing materials, creating a customer complaint database, and responding to regulatory and legal inquiries and challenges. Before joining Sears, Mr. Weiss served 13 years as an Assistant or Deputy Attorney General in the States of Kansas, Texas and Missouri, four years as an Assistant District Attorney in Topeka, Kansas, and two years as an Associate Counsel for the National Association of REALTORS®. You can find Art on LinkedIn here.

Tom and Kortney sit down in Minneapolis to discuss Tom’s new ambassadorship and his newest venture, his leadership podcast – 12 O’Clock High. They also discuss the impact of generations on leadership styles, including: * How a World War II movie inspired a podcast about leadership; * Why leaders need help; * How leadership is changing; * How we’ve gone from a sense of shared sacrifice to the “me” culture of millennials; * Why generational insights are important leadership tools; * The challenges of leading cross-generational teams; * Using history to teach us leadership lessons; * The benefits (or not) of communicating face-to-face; * How to synthesize what we need from our leaders; * Responding to your employees in a way they understand; and * The impact of the big data and social media on leadership. Thomas Fox has practiced law in Houston for 30 years. He is now the Compliance Ambassador for the Red Flag Group.Tom is the author of the award winning FCPA Compliance and Ethics Blog and the international best-selling book “Lessons Learned on Compliance and Ethics”. His seminal book, “Doing Compliance: Design, Create, and Implement an Effective Anti-Corruption Compliance Program” is widely viewed as one of the top one-volume books on the nuts and bolts of compliance. He is one of the top leaders in social media in compliance, blogging, podcasting, writing and speaking across the globe on anti-corruption and anti-bribery compliance programs. He frequently shares his insight and wisdom by speaking and writing for SCCE. His new podcast, 12 O’Clock High (http://www.12oclockhighleadership.com/) explores what it means to be a leader. Many in business think that if you’re not born with the right leadership traits you can never successfully lead. The opposite is actually the truth. Leadership skills CAN be learned, and in each episode Tom explores the techniques of leadership, to incorporate them into your own business strategy.

Taped live at SCCE’s 2016 Compliance & Ethics Institute (so please excuse some background noise and elevator music), The Red Flag Group’s CEO and Chairman, Scott Lane sits down with Kortney Nordrum to discuss: * Compliance changes through the last decade; * The importance of certification and knowing your stuff; * Measuring the effectiveness of your compliance program; * The benefits of being positive-looking in your program; * The development of outsourcing in compliance; * Embedding compliance into the fabric of your business; * The benefit of focusing on a few things, instead of trying to be a jack-of-all-compliance-trades; * Using risk to prioritize your compliance resources; * The biggest risk in the current compliance landscape (hint: it probably relates to money); and * Challenging the CEO to join the compliance team. Scott has over 15 years’ experience in legal, compliance, internal audit, export control, ethics and corporate governance, providing counsel and advice to senior management throughout the world in the development of legal and compliance practices. Scott has worked as a senior director and general counsel in various multinational corporations in Australia, the United Kingdom and Hong Kong, and has significant experience in complex compliance issues. Scott has worked in several industries, ranging from insurance to high technology. He has spoken at over 100 conferences on compliance in the United States, the United Kingdom, Australia, Hong Kong, Singapore, China, India, Indonesia, the United Arab Emirates, and Qatar. Scott is an avid writer, and has had over 100 articles published in leading newspapers and journals, including The Red Flag Group’s own Compliance Insider® of which he is the publisher and Editor-in-Chief. Scott has led training sessions on compliance, corporate governance, director duties, antitrust compliance and anti-corruption compliance in multiple countries. These sessions have involved small groups of less than 10 people through to sessions of over 600 people and involving entire businesses. You can find Scott and The Red Flag Group here.  

Taped live at SCCE’s 15th Annual Compliance & Ethics Institute, Tom & Roy get a chance to interact with a live audience and bounce from topic to topic, discussing: * The breadth and depth of wisdom from the general session speakers this year (a little self-promotion never hurts); * What Bill Baer (Principal Deputy Associate Attorney General, U.S. Department of Justice) suggests to keep the DOJ out of your hair; * The pervasiveness of modern slavery and human trafficking (Hint: think about how many slaves are in the US right now? Now triple that number. You’re still low.); * Then on to Kristy Grant-Hart and her infectious passion for compliance; * What it means to attend the CEI and be “with your people;” * The difference between being older than soil and older than dirt; * Why we can’t give Roy pens that make noise; * An in-depth discussion of the Wells Fargo scandal; * A hard look at whether compliance officers should be involved in setting the salary of CEOs; * Arnold Palmer and the culture of ethics; * How can we continue to encourage and celebrate ethical individuals?; * Whistleblowers and the first-time front-pay award, asking how much pain do the companies have to feel to stop encouraging unethical behavior?; and * Should compliance officers sit on the nomination committee and help choose the C-suite? The board? Thomas Fox has practiced law in Houston for 30 years. He is now the Compliance Ambassador for the Red Flag Group.Tom is the author of the award winning FCPA Compliance and Ethics Blog and the international best-selling book “Lessons Learned on Compliance and Ethics”. His seminal book, “Doing Compliance: Design, Create, and Implement an Effective Anti-Corruption Compliance Program” is widely viewed as one of the top one-volume books on the nuts and bolts of compliance. He is one of the top leaders in social media in compliance, blogging, podcasting, writing and speaking across the globe on anti-corruption and anti-bribery compliance programs. Roy Snell (roy.snell@corporatecompliance.org) is the CEO of the Health Care Compliance Association (HCCA) and the Society of Corporate Compliance and Ethics (SCCE), which together now total more than 17,000 members. Roy was a co-founder and the organization’s first President. He has developed numerous partnerships with government, industry, and other professional associations, and he has facilitated collaboration between the compliance/ethics profession and the enforcement community. Roy has a Masters degree in Health and Human Services Administration. Through his work with the two associations, he has overseen the development of compliance and ethics books, manuals, videos, conferences and audio conferences. He has been a regular speaker in the compliance profession for more than ten years and has spoken internationally for the United Nations on compliance and ethics. He is a Certified Compliance and Ethics Professional (CCEP)®. Roy writes more than 25 compliance articles annually and has written for several international publications, including European CEO and The European Business Review. Roy is the co-editor of the Health Care Compliance Professional’s Manual and serves as editor, co-editor and advisory board member of several other books, magazines and newsletters. He has served as a source for many media reports, including national publications such as the Wall Street Journal, Forbes Magazine and Business Week. He has been quoted in international publications such as Financial Times and Ethical Corporation.

SCCE Compliance & Ethics Institute speaker and CEO of Front-Line Anti-Bribery LLC, Richard Bistrong and host Kortney Nordrum discuss the nuances of understood versus defensible compliance, including: * Richard’s fascinating past; * Why he was compelled to join the compliance and ethics fight; * How to do your job well, and still follow the rules (even in sales) reflecting on the recent Unfair & Unbalanced Podcast; * The results of SCCE’s Compliance & Ethics Program Objectives Survey; * What the survey tells us about morale in the compliance department; * The importance of training and providing opportunities to speak up; * The differences between defensible and understood compliance; * Who fights for which; and * Why we need both. For more information on SCCE’s Compliance & Ethics Institute, taking place September 25-28 in Chicago, click here. To view SCCE’s full Compliance & Ethics Program Objectives Survey, click here. To listen to episode 8 of Unfair & Unbalanced, click here. In Richard’s own words: I bribed foreign officials, cooperated with international law enforcement & went to prison. Today, I share that front line experience for the benefit of others who confront overseas corruption risk in the field, & for those compliance professionals & practitioners tasked with helping them to manage risk. My consultancy, Front-Line Anti-Bribery, LLC is based on my experience which includes 10+ years as an International Sales Executive, & an extended period of covert cooperation with US & UK law enforcement. I elevate that perspective, through my writings & presentations, in order to bring value to current anti-bribery compliance challenges. I speak to real-world emotions, temptations & rationalizations that are not often discussed, understood or addressed by compliance personnel & C-Suite occupants. Thus, it is a complement to existing legal, audit and regulatory compliance efforts and programs. I ask: Is compliance viewed as “bonus prevention” by your international business teams? In other words, is compliance, business strategy & incentive compensation properly aligned? Do your front line business teams view compliance as nothing but a “bolt-on” set of rules & procedures where they ponder “what does management really want” at the field level? Is the international front line being properly trained & drilled in the real-world identification of the red-flags, hazards & early warnings of bribery activity & corruption risk? My goal is to bring value to current anti-bribery efforts by sharing my experience & perspective in how bribery is confronted at the front lines of business. By hearing a first hand account, Executives & Compliance Personnel will then have a “clear eyed” behavioral view of how bribery is rationalized in the field of overseas business. For more information feel free to e-mail Richard at Richardtbistrong@gmail.com

Ahead of HCCA’s Healthcare Enforcement Compliance Institute, speaker Sean McKenna and host Kortney Nordrum discuss the importance of medical necessity and quality of care compliance, including: * What an effective healthcare compliance program look like; * The history of medical necessity compliance and the changes under the ACA; * Quality of care benchmarks; * How compliance programs help eliminate quality of care enforcement concerns; * Criminal and civil liabilities for quality of care and necessity issues (including the importance of understanding kickbacks); * Who the DOJ actually indicts; * The importance of documentation and peer review standards; * Recent compliance concerns; and * Sean’s best advice to measure your program’s effectiveness. Sean McKenna ia a shareholder in Greenberg Traurig’s Dallas office. Sean focuses his practice on healthcare enforcement and regulatory issues, representing individuals and providers under civil or administrative investigation by the Department of Justice, Offices of Inspector General, and Attorneys’ General Medicaid Fraud Control Units, as well as in criminal investigations and matters involving the United States and State Attorneys General. As a former ten-year Assistant United States Attorney, Associate Counsel to the Inspector General and General Counsel for the U.S. Department of Health and Human Services, Sean focuses his practice on matters involving the health care industry and regularly represents clients before Medicare, Medicaid and commercial contractors. Sean’s work includes assisting clients with internal investigations and compliance reviews, as well as advising on compliance with state and federal fraud and abuse rules. He is a frequent invited speaker at national, regional, and local conference. Sean has been Vice-Chair of the ABA Health Law Section’s Membership Committee and a member of the State Bar of Texas’s Health Law Section Council since 2013. He was honored in 2015 and 2016 to be named a Best Lawyer in America, Healthcare Litigation, and Texas SuperLawyer for healthcare in 2016. For more information on HCCA’s Healthcare Enforcement Compliance Institute, click here.

Recorded live at the FBI Compliance Academy in Washington, DC, FBI Assistant Director and Chief Compliance Officer, Office of Integrity and Compliance (OIC), Patrick Kelley and host Kortney Nordrum discuss the inception, building, and growth of the FBI’s integrity and compliance, including: * What the Office of Integrity and Compliance (OIC) is and what they do; * How to train and educate 35,000 employees in 56 field offices and 70+ legal attaches; * The structure and hierarchy of leadership in the FBI and the OIC, and who holds them accountable; * How the OIC identifies and assesses risk; * The process for internal and external audits of the OIC; * The FBI Ethics Program; * The importance of building and growing your compliance and ethics program; * Benefits on non-punitive self-disclosure; * OIC’s 5-year Strategic plan; and * Measuring impact and success in the FBI compliance program. Prior to joining the FBI in 1994, Patrick W. Kelley served for 21 years in the U.S. Navy as a member of the Judge Advocate General’s Corps. He began his career in the Navy in 1973 as the Station Judge Advocate at Naval Air Station, Moffett Field California. He served there until 1977 when he was transferred to Naval Base, Yokosuka, Japan, where he was a prosecutor and international law officer. In 1981, Mr. Kelley was promoted and transferred to the Naval Justice School, Newport, Rhode Island, where he served as an instructor until 1983. The Navy selected Mr. Kelley for post-graduate schooling in Philadelphia, Pennsylvania, and then sent him to the Office of the Judge Advocate General in Washington, D.C., to serve as the head of the Standards of Conduct and Legislation Branches. Mr. Kelley was promoted again and selected to serve as the Commanding Officer of Naval Legal Service Office, Groton, Connecticut, in 1988. In 1991, Mr. Kelley was promoted to the rank of Captain (O-6) and transferred to the Pentagon where he finished his naval career as the Deputy Assistant Judge Advocate General for Administrative Law. After retiring from the Navy in 1994, Mr. Kelley joined the FBI Office of General Counsel (OGC) as an attorney-advisor in the Administrative Law Unit. He was selected as unit chief of that unit in 1995. Three years later, Mr. Kelley was promoted to the Senior Executive Service. As a deputy general counsel, Mr. Kelley led the General Law and Legal Training Branch. He also served as the OGC Chief of Staff, the FBI Component Designated Agency Ethics Official, and Senior Privacy Officer. In the summer of 2007, Mr. Kelley was asked to lead the newly created Office of Integrity and Compliance, where he currently serves. Mr. Kelley holds a Bachelors of Science degree from Michigan State University, a Juris Doctor degree from Duke University, a Masters of Law degree from the University of Pennsylvania, and a Masters of Business Administration degree from George Washington University. He was given a Legion of Merit medal by the Navy in 1994 and a Meritorious Executive award by the FBI in 2003.