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Unformatted text preview: July 2007 42 Editors note: Nick Ciancio is Senior Vice Presi- dent, Marketing and Business Development at Global Compliance Services. He may be reached by e-mail at or by telephone at 800/876-6023. E ffective ethics and compliance pro- grams are key factors in achieving a culture of integrity within your health care organization. In addition to estab- lishing ethical and compliant behavior and regulating against noncompliance, these pro- grams, as expressed by the Office of Inspector General (OIG), are a major initiative in engaging the private health care community in combating fraud and abuse. 1 What is the magic recipe for an effective ethics and compliance program? Every health care organization has its own customized plan, but if you look at the basis of each, you will find the Seven Pillars under every foundation. So where did these seven elements come from? Did the ethics and compliance genie cast them from his lamp of gold? Not exactly. The Seven Pillars of an effective ethics and compliance program originated out of the formation of the U.S. Sentencing Commis- sion (USSC) in 1984 by Congress in an effort to create enforceable, universal sentencing guidelines for comparable crimes. After establishing Federal Sentencing Guidelines for Individuals in 1987, the formi- dable body sanctioned Federal Sentencing Guidelines for Organizational Defendants (Guidelines) in 1991, which apply to public, private, not-for-profit, and government organizations convicted of federal crimes. Additional amendments were enacted in 2004 giving stronger credence to an effective compliance program, promoting a culture of compliant and ethical behavior, and exercising due diligence to prevent and detect criminal conduct. This was a substantial mandate, considering corporate sentencing had been in complete chaos with almost identical cases being han- dled differently. The Commission realized the need to address the disparate sentencing and approached the development of guidelines with three objectives: (1) to define a model for good corporate citizenship; (2) to utilize this model to ensure corporate sentencing is fair by providing objective, definable criteria; and (3) to employ the model to create incen- tives for organizations to self-initiate crime prevention action....
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This note was uploaded on 01/30/2011 for the course GEB 6376 taught by Professor Kest during the Spring '10 term at Hodges University.

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