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The New OIG “Responsible Corporate Officer Doctrine ...
- https://www.compliance.com/resources/the-new-oig-responsible-corporate-officer-doctrine/
- In his keynote address at the Annual Compliance Institute of the Health Care Compliance Association (“HCCA”), the Inspector General highlighted the responsible corporate officer doctrine, and proclaimed that “the OIG is focused on holding responsible corporate officials accountable for health care fraud.”Estimated Reading Time: 10 mins
T H The New OIG “Responsible Corporate Offi cer Doctrine”
- http://compliance.com/wp-content/uploads/2011/01/JHCC_01-11_Herrmann1.pdf
- Inspector General (OCIG). For more information, see www.strategicm.com or call him directly at 703/535-1410. EXCLUSION TOM HERRMANN The New OIG “Responsible Corporate Offi cer Doctrine” Compliance Offi cers Need to Ensure Executive Leaders Are Briefed on the Signifi cance of the New Doctrine T he Department of Health and Human Services
Responsible Corporate Officer: Not Just A Criminal Concept ...
- https://www.primerus.com/business-law-articles/responsible-corporate-officer-not-just-a-criminal-conscept-02212012.htm
- Utilizing the responsible corporate officer doctrine, the OIG has been taking an increasingly aggressive stance in seeking to debar individuals who have not been convicted of a felony, and in once instance have not been convicted of anything at all. The case of Freidman v. Sebelius, 755 F.Supp. 2nd 98 (D.D.C. 2010) is illustrative.
The Resurgence of the Responsible Corporate Officer Doctrine
- https://hawleytroxell.com/2012/06/the-resurgence-of-the-responsible-corporate-officer-doctrine/
- Jun 14, 2012 · Aptly referred to as the crime of doing nothing, the RCO doctrine is a strict-liability theory used by the government to bring misdemeanor charges against officers and directors who fail to prevent or correct a corporation’s misconduct.
Corporate Compliance Officer Liability Under the ...
- https://healthlawfla.com/2012/08/09/corporate-compliance-officer-liability-under-the-responsible-corporate-officer-doctrine-2/
- Aug 09, 2012 · Significantly, the executives’ liability was founded solely on the “responsible corporate officer” doctrine. The responsible corporate officer doctrine provides that an individual may be charged with a crime for violating the law simply by virtue of his or her position within a company.
THE REVIVAL OF THE RESPONSIBLE CORPORATE OFFICER …
- https://www.goodwinlaw.com/~/media/Files/Publications/Attorney%20Articles/2013/Revival%20of%20the%20RCO%20Doctrine_Savage%20Klawiter.pdf
- The Park Doctrine…provides that a responsible corporate official can be held liable for a first time mis-demeanor…under the [FDCA] without proof that the corporate offi-cial acted with intent or even negligence, and even if such corpo-rate official did not have any actual knowledge of, or participation in, the specific offense.20
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