In many companies, the compliance officer is the first to become aware of a potential compliance problem that could lead to civil or criminal liability. A best practice is to give the compliance officer the authority to conduct internal investigations.
The application of attorney-client privilege is somewhat more complicated in situations where the client is a corporation. Although corporations are entitled to the same protection of confidentiality as noncorporate clients, the application of the privilege often turns on which corporate officials and employees sufficiently personify the corporation as a client.
Medicare made $54.4 million in improper payments to acute care hospitals for post-acute transfers that did not comply with Medicare’s policies, according to a November 1 report from the Office of Inspector General (OIG).
