Michael Dowell Authors "New Federal Sentencing Guidelines Requirements for an Effective Compliance Program" in Compliance Today
In The News | 1 min read
Sep 15, 2010
Health care organizations face a daunting array of statutes and regulations, including the False Claims Act, federal and state anti-kickback statutes, self-referral prohibition, fraud and abuse laws, federal and state privacy and security laws including the Health Insurance Portability and Accountability Act (HIPAA) Privacy and Security requirements, corporate practice of medicine prohibitions, and licensing laws. In order to comply with these laws, most health care organizations have adopted compliance programs designed in accordance with the standards for an “effective” compliance program under the Federal Sentencing Guidelines (FSG).
The United States Sentencing Commission’s (USSC’s) recent amendments to its FSG Manual will have significant implications for health care organizations that are seeking to obtain leniency based on the maintenance of effective compliance programs. The amendments make important changes to the construct of an “effective” compliance program, focusing on: (1) board reporting relationships of the compliance officer; and (2) actions health care organizations should take following detection of criminal conduct. Unless overturned by Congress, the new amendments take effect on November 1, 2010.
This article, published in Compliance Today, appears here with permission from the Health Care Compliance Association. Call HCCA at 888/580-8373 with all reprint requests
Related People
Featured Insights

Healthcare Alert
Aug 3, 2026
Fixing the Emergency Refill Trap: What California’s AB 1587 Means for Pharmacies

Consumer Crossroads: Where Financial Services and Litigation Intersect
Jul 30, 2026
Should Text Messages be Considered “Calls” Under the TCPA? The Seventh Circuit Says No

Healthcare Alert
Jul 30, 2026
California Courts Sharply Curtail the MICRA Damages Cap in Nursing Home Litigation

Insights for Insurers Alert
Jul 30, 2026
Analyzing a Couple of Cases Involving Exclusions in D&O Policies

In The News
Jul 29, 2026
Hinshaw Authors Contribute Two Articles in Latest Edition of the CCFL Quarterly Report

Webinar
Jul 28, 2026
Cathy Mulrow-Peattie and Sabrina Janeiro Present on Legal AI Technology

In The News
Jul 27, 2026
Scott Seaman Discusses How the Insurance Industry Contributed to the 2026 FIFA World Cup

Privacy, Cyber & AI Decoded Alert
Jul 27, 2026
Compliance Guidance for the New Vermont Data Privacy and Online Surveillance Act (VDPOSA)

Healthcare Alert
Jul 24, 2026
Q&A: Right to Electronic Monitoring Extended to Illinois Assisted and Shared Living Facilities

Press Release
Jul 23, 2026
Insurance Partner Christophe Burusco Joins Hinshaw in Los Angeles

In The News
Jul 16, 2026
Jennifer Driscoll Anticipates Epic Battle Between “Titans of the Antitrust Bar”


