SunHawk's HHS OIG Audit Summary Reports - Provider and Payer April 2021 Update

HHS OIG Office of Audit Services and Office of Evaluation and Inspections issues approximately 300 audits and evaluations a year. The findings and recommendations provided herein are extracted from the specific audits included in this report and referenced by their respective report numbers at the end of each abstract. SunHawk’s reports summarize completed audits and evaluations over the last 12 months and sorts relevant audits into the Provider and Payer categories. For the PROVIDER-FOCUSED Completed Audit Summary Report CICK HERE For the PAYER-FOCUSED Completed Audit Summary Report CLICK HERE SunHawk’s team of experts are always available to offer their assistance. To stay apprised of the future reports subscribe to our newsletter and follow us on LinkedIn. If additional information would make this report more valuable to you, please reach out and give us your thoughts. Kimulet.Winzer@SunHawkConsulting.com James.Rose@SunHawkConsulting.com Jan.Elezian@SunHawkConsulting.com Jim@SunHawkConsulting.com SunHawk Consulting is a team of highly skilled and experienced subject matter experts in the Healthcare, Life Sciences, and Insurance Industries who understand that the client’s needs come first. SunHawk provides Crisis Management Response, Compliance Consulting, Disputes & Investigations, and Staff Augmentation services for Boards of Directors, internal/external legal counsel, company management, special committees, and government agencies.

SunHawk's Compliance Effectiveness Tool

SunHawk Consulting's Compliance Assessment Tool is their proprietary guide for corporate compliance! This tool is a crosswalk to June 2020 DOJ key regulatory expectations on the evaluation of compliance programs, and therefor, should factor into your program's metrics. Use this tool annually to evaluate the current state of your organization’s Compliance Program and establish any considerations for continuous improvement. SunHawk is offering their Compliance Effectiveness Tool, for free! Ramping Up Virtual Project Management / Team Facilitation in Response to COVID-19? SunHawk Can Help! Our skilled leaders and professionals at SunHawk are experts at managing complex and time sensitive projects in a virtual on-line world. In these disruptive times, we can jump in to help your organization with regulatory and compliance management needs including: · Organizing a short-term crisis management/response team, · Facilitating or assuming leadership of a new compliance initiative, or · Providing leadership to an established team or adding additional expertise. Do you have work that needs to be done? Do you not have the immediate bandwidth or resources to see such projects to fruition given other priorities? We can help, please reach out to Jim Rough or James Rose for assistance: Jim@SunHawkConsulting.com James.Rose@SunHawkConsulting.com SunHawk Consulting is a team of highly skilled and experienced subject matter experts in the Healthcare, Life Sciences, and Insurance Industries who understand that the client’s needs and budgets come first. SunHawk provides Crisis Management Response, Compliance Consulting, Disputes & Investigations, and Staff Augmentation services for Boards of Directors, internal/external legal counsel, company management and employees, special committees, bankruptcy trustees and receivers, and government agencies.

Responding to Inappropriate Behavior with an Appropriate Response by Martin Biegelman

The February 2021 announcement of the resignation of the CFO from global healthcare leader Eli Lilly for an inappropriate personal though consensual relationship shows how good can come from bad. Organizations cannot completely stop all inappropriate employee behavior, but they can positively influence appropriate conduct now and for the future. Eli Lilly had a swift response to allegations of CFO misconduct. The board commenced a comprehensive independent investigation with outside counsel and confirmed the allegation. The CFO was forced out, and the company declared that violations of their core values by any employee, and especially executive officers, will not be tolerated. While this is the most recent revelation of an executive ouster for inappropriate conduct with employees, unfortunately it will not be the last. Over the last few years there have been an increasing number of corporate officers who have been the subject of internal investigations for improper consensual relationships. In June 2018, Intel’s then CEO resigned after a consensual relationship with an employee in violation of company policy was uncovered. In February 2019, outdoor retailer REI’s CEO resigned for failing to disclose a personal relationship with another executive. In November 2019, McDonald’s fired its CEO for similar inappropriate conduct with an employee. The common denominator for all these cases included: Someone felt comfortable to confidentially or anonymously report a violation of company policy even though it involved a senior executive; The allegation was escalated to the board of directors; The board quickly responded with an independent investigation led by outside counsel; The investigation determined that the allegation was founded; Disciplinary action was handed down with removal of the senior executive; and The company disclosed the misconduct and the outcome to the public. There are important lessons for business organizations. Corporate officers and boards should look at the increasing number of reporting of code of conduct violations, including inappropriate personal and consensual behavior, as a good thing. Organizations need to quickly learn of concerns and issues that may require investigation. For that to happen, employees need to feel safe and empowered to report their concerns and issues, and to know there will be no retaliation for reporting in good faith. At its core, there needs to be organizational justice and employees need to be confident that it is exists for everyone, no matter their title. The Criticality of Organizational Justice Organizational justice involves employees’ perception of fairness in the workplace. It includes how an internal investigation is conducted, how outcomes are determined with impartiality and integrity, and how those outcomes are communicated to employees. Organizational justice also includes the actions of the investigators involved and that they must be unbiased. The subject and witnesses of the investigation must understand that the investigation process is fair, and any disciplinary action is based only on the evidence. In cases involving senior management, it is imperative that no special treatment is given because of executive status. Without organizational justice, employees will not believe that the investigation process is fair and just. As a result of the #MeToo movement, we have seen that organizational justice has not always been present for those reporting sexual harassment and assault allegations. The Importance of an Independent Investigation An independent investigation is needed when the subject of the investigation is the CEO, CFO, or other senior leader who may have directed, condoned, or knew about the alleged misconduct and did not act. An independent investigation is directed by a committee of the board of directors such as the audit committee or a special committee of the board. This board committee should select and retain independent counsel. Experienced forensic investigative consultants should also be retained to assist counsel. An investigation conducted by the general counsel, disclosure counsel, or management is per se not independent. The Department of Justice and the Securities and Exchange Commission have opined about bringing enforcement actions against corporate management for misconduct, so an independent investigation is warranted whenever management could face regulatory scrutiny. The DOJ and the SEC value independent investigations and can reward those organizations that conduct such an investigation. #MeToo Is More Than Just a Hashtag It is not just accusations of inappropriate personal and consensual relationships that companies have had to respond to. Allegations of sexual harassment and assault are some of the most pressing issues that organizations of all kind have and will continue to face. Yet, organizations have not always thoroughly investigated such allegations when they arose. Accusers have been ignored, they have been put on the defensive, and have faced retaliation for reporting these offenses. But times are changing. It took the revelations of sexual harassment and assaults perpetrated by Hollywood celebrities, television personalities, politicians, and corporate titans to spur a movement and bring much needed change in how organizations effectively address this egregious and illegal behavior. The #MeToo movement has reinforced the need for timely, thorough, and professional fact investigations and an appropriate remedial response if allegations are founded. The hope is that no one, no matter their position, accomplishments, or prominence, is beyond the reach of organizational justice. Not only are we beginning to see change when it comes to how sexual harassment allegations are handled, but we are seeing swifter action and resolution. Take the recent case of Moncef Slaoui. You may not know his name, but you are likely familiar with his role during the COVID-19 pandemic. Dr. Slaoui was the U.S. government’s chief scientist for Operation Warp Speed that spearheaded development of the COVID-19 vaccines until his departure in January 2021. He also spent 30 years at pharmaceutical giant GlaxoSmithKline (“GSK”) working in vaccine research and development. After his departure from Operation Warp Speed, he returned to his role as chairman of the board of a biotechnology company financed by GSK. In February 2021, GSK received “a letter containing allegations of sexual harassment and inappropriate conduct towards an employee of GSK by Dr. Slaoui, which occurred several years ago when he was an employee of GSK.”[i] GSK immediately retained a renowned law firm to investigate the allegations. While GSK did not release the details of the internal investigation, what we do know is that the law firm’s investigation quickly confirmed the allegations and in March 2021, Dr. Slaoui was fired from GSK. GSK issued a press release about the termination and that the investigation is continuing. The GSK CEO also sent a letter to all employees informing them of the firing and stated, “I want to be clear that sexual harassment is strictly prohibited and will not be tolerated.”[ii] The CEO reinforced that message by announcing that Dr. Slaoui’s name was removed from the company’s research and development center. It is essential to conduct an independent investigation, especially if senior executives are the subjects of sexual assault and harassment allegations. There is no excuse for not conducting an immediate investigation of a credible allegation. Since these allegations are potential criminal violations, law enforcement involvement is likely and even more reason to conduct an appropriate investigation. A flawed investigation will come back to haunt those responsible. In addition, updating the victim or complainant to the extent possible on an ongoing basis is a best practice in building trust for the investigation process no matter the allegation. I know of a public company that has a dedicated unit that keeps employees who have reported compliance issues informed of the investigation status. After the conclusion of the investigation and for an extended period, the contact continues to ensure that no retaliation has occurred. Unfortunately, those who retaliate have long memories. It’s Not Over Until There is Remedial Action At the conclusion of the investigation, remediation is a necessity. All too often, an internal investigation concludes without using the investigative results as a learning opportunity to determine the origin of the issue and use that finding to reduce the risk of reoccurrence. The DOJ’s Evaluation of Corporate Compliance Programs, updated June 2020, states that “a hallmark of a compliance program that is working effectively in practice is the extent to which a company is able to conduct a thoughtful root cause analysis of misconduct and timely and appropriately remediate to address the root causes.” Remediation is a key factor that the DOJ and the SEC considers in determining a company’s cooperation efforts when under investigation. Remedial actions are more than just stopping the misconduct and disciplining or terminating wrongdoers. In its best form, remediation includes modifying and improving policies, procedures, and internal controls. It includes training of employees as well as vendors, contractors, partners and other third parties that do business with the organization. It involves fair and balanced discipline. Besides disciplinary processes, there must be an appropriate incentive program to promote a culture of integrity, accountability, and compliance. Ultimately, it includes an assessment and enhancement of the ethics and compliance program to lessen the risk of regulatory, financial, litigation and reputational risk. As the Evaluation of Corporate Compliance Programs further asks, “What specific changes has the company made to reduce the risk that the same or similar issues will not occur in the future?” and “What specific remediation has addressed the issues identified in the root cause and missed opportunity analysis?” Although not often done, organizations should consider releasing a redacted version of the investigation report. This demonstrates transparency and reinforces a commitment to core values, policies, and procedures, and sends a strong message to employees. For example, in 2012 an independent investigation by consumer electronics retailer Best Buy found that the then CEO had engaged in a personal relationship with a subordinate in violation of company policy. The CEO quickly resigned. The company’s board decided “in the interest of transparency and accountability” to release the audit committee’s findings of the investigation.[iii] The failure to take appropriate and timely action to allegations of sexual harassment and assault can have a lasting impact, to say nothing of the financial and reputational damage. In March 2021, the University of Southern California (“USC”) announced it will pay $1.1 billion to settle lawsuits from 710 women for sexual abuse committed against them by a former campus gynecologist. The settlement has been called ”the largest sexual abuse settlement against any university and the largest personal injury settlement against any university in history.”[iv] Although the accused has been criminally charged for his conduct, a federal investigation by the U.S. Department of Education’s civil rights office found that USC failed to act on numerous allegations of sexual abuse with some going back 20 years. The government’s investigation found that USC “failed to investigate warnings from at least nine patients about Tyndall’s conduct between 2000 and 2009.”[v] Even when damning evidence was found, the university did not act. In 2016, “the university discovered over 200 photos of patients’ genitals in Tyndall’s office but didn’t investigate that either and allowed him to continue to see patients.”[vi] This speaks volumes about the absolute necessity for a timely and professional inquiry to allegations of sexual abuse, as well as all alleged misconduct. The axiom of justice delayed is justice denied has never been truer. When it comes to responding to inappropriate behavior with an appropriate response, be sure to remember a forewarning from Warren Buffett: “It takes 20 years to build a reputation and five minutes to ruin it. If you think about that, you’ll do things differently.” [i] “Moncef Slaoui Departs Galvani Bioelectronic Board of Directors,” GlaxoSmithKline plc Press Release, March 24, 2021, https://www.gsk.com/en-gb/media/press-releases/moncef-slaoui-departs-galvani-biolelectronics-board/. [ii] Dan Mangan, “GSK fires Trump Covid vaccine chief Moncef Slaoui for ‘substantiated sexual harassment claims,” CNBC.com, March 24, 2021, https://www.cnbc.com/2021/03/24/moncef-slaoui-fired-from-galvani-bioelectronics-board-of-directors-over-sexual-harassment-allegations.html. [iii] “Best Buy Releases Results of Independent Investigation; New Chairman of the Board Elected,” Best Buy Co., Inc., May 14, 2012, https://www.businesswire.com/news/home/20120514005889/en/Best-Buy-Releases-Results-of-Independent-Investigation-New-Chairman-of-the-Board-Elected. [iv] Claire Colbert and Cheri Mossburg, “George Tyndall: USC will pay $1.1 billion to settle lawsuits for sexual misconduct against former campus gynecologist,” MSN.com, March 26, 2021, https://www.msn.com/en-us/news/us/george-tyndall-usc-will-pay-1-1-billion-to-settle-lawsuits-for-sexual-misconduct-against-former-campus-gynecologist/ar-BB1eXUas?ocid=uxbndlbing. [v] Tyler Kingkad, “USC mishandled gynecologist’s sexual abuse reports for decades, feds say,” NBCNews.com, February 27, 2020, https://www.nbcnews.com/news/us-news/usc-mishandled-tyndall-sexual-abuse-reports-decades-feds-say-n1144531. [vi] Ibid. About Martin Biegelman Martin Biegelman, CFE, CCEP Managing Director SunHawk Consulting, LLC Martin.Biegelman@SunHawkConsulting.com Martin Biegelman has spent a lifetime detecting, investigating, and preventing fraud and corruption in various leadership roles in law enforcement, consulting, and the corporate sector. His work on behalf of corporate management and boards includes conducting internal investigations, including independent investigations, alleging fraud, corruption, Foreign Corrupt Practices Act violations, conflicts of interest, whistleblower retaliation, and other employee and vendor misconduct. Martin’s work also includes developing, assessing, and enhancing corporate compliance and ethics programs including internal investigative and anti-bribery compliance programs, as well as performing fraud risk assessments. Click Here to view Martin's full bio SunHawk Consulting and its compliance consultants and advisors are highly experienced in conducting independent investigations with outside counsel. Their experience includes financial accounting fraud, conflicts of interest, inappropriate personal relationships, harassment, whistleblower retaliation, and other organizational code of conduct violations. Our subject matter experts can provide insight into your specific risk and other compliance program needs. We are happy to have a discussion with you and determine how we can possibly assist you in responding to and mitigating risk.

SunHawk's OIG Work Plan March 2021 Update

HHS OIG Office of Audit Services and Office of Evaluation and Inspections issues approximately 300 audits and evaluations a year. The OIG Work Plan sets forth various projects, including OIG audits and evaluations, that are underway or planned to be addressed during the fiscal year and beyond. SunHawk's OIG Work Plan Summary Report summarizes currently active Work Plan items and sorts relevant Work Plans items into Provider and Payer categories. CLICK HERE to download the OIG Work Plan Summary Report for PROVIDERS CLICK HERE to download the OIG Work Plan Summary Report for PAYERS SunHawk’s team of experts are always available to offer their assistance. To stay apprised of the future reports subscribe to our newsletter and follow us on LinkedIn.

If additional information would make this report more valuable to you, please reach out and give us your thoughts.

Jan.Elezian@SunHawkConsulting.com Kimulet.Winzer@SunHawkConsulting.com
Jim@SunHawkConsulting.com

SunHawk Consulting is a team of highly skilled and experienced subject matter experts in the Healthcare, Life Sciences, and Insurance Industries who understand that the client’s needs come first. SunHawk provides Crisis Management Response, Compliance Consulting, Disputes & Investigations, and Staff Augmentation services for Boards of Directors, internal/external legal counsel, company management, special committees, and government agencies.

Corporate Integrity Agreement (CIA) Summary Report - March 2021 Update

The United States Government requires Corporate Integrity Agreements (CIA) for health care Providers, Payers and Life Science companies when settling allegations of false claims related to quality of care or corporate integrity issues, against various Federal health care programs. Under the terms of a CIA, companies agree to various obligations including, in most cases, the engagement of an Independent Review Organization. The CIA summaries provide focused insights into healthcare related Corporate Integrity Agreements (CIA) settled over the last couple of years and are extracted from published CIAs and US Department of Justice press releases. CLICK HERE to view the PROVIDER Corporate Integrity Agreement (CIA) Summary CLICK HERE to view the LIFE SCIENCE Corporate Integrity Agreement (CIA) Summary SunHawk’s team of experts are always available to offer their assistance. To stay apprised of the future reports subscribe to our newsletter and follow us on LinkedIn. If additional information would make this report more valuable to you, please reach out and give us your thoughts. Martin.Biegelman@SunHawkConsulting.com Jan.Elezian@SunHawkConsulting.com James.Rose@SunHawkConsulting.com Jim@SunHawkConsulting.com SunHawk Consulting is a team of highly skilled and experienced subject matter experts in the Healthcare, Life Sciences, and Insurance Industries who understand that the client’s needs come first. SunHawk provides Crisis Management Response, Compliance Consulting, Disputes & Investigations, and Staff Augmentation services for Boards of Directors, internal/external legal counsel, company management, special committees, and government agencies.

SunHawk's HHS OIG Audit Summary Reports - Provider and Payer March 2021 Update

HHS OIG Office of Audit Services and Office of Evaluation and Inspections issues approximately 300 audits and evaluations a year. The findings and recommendations provided herein are extracted from the specific audits included in this report and referenced by their respective report numbers at the end of each abstract. SunHawk’s reports summarize completed audits and evaluations over the last 12 months and sorts relevant audits into the Provider and Payer categories. For the PROVIDER-FOCUSED Completed Audit Summary Report CLICK HERE For the PAYER-FOCUSED Completed Audit Summary Report CLICK HERE SunHawk’s team of experts are always available to offer their assistance. To stay apprised of the future reports subscribe to our newsletter and follow us on LinkedIn. If additional information would make this report more valuable to you, please reach out and give us your thoughts. Kimulet.Winzer@SunHawkConsulting.com James.Rose@SunHawkConsulting.com Jan.Elezian@SunHawkConsulting.com Jim@SunHawkConsulting.com SunHawk Consulting is a team of highly skilled and experienced subject matter experts in the Healthcare, Life Sciences, and Insurance Industries who understand that the client’s needs come first. SunHawk provides Crisis Management Response, Compliance Consulting, Disputes & Investigations, and Staff Augmentation services for Boards of Directors, internal/external legal counsel, company management, special committees, and government agencies.

SunHawk's OIG Work Plan March 2021 Update: Provider Focused

HHS OIG Office of Audit Services and Office of Evaluation and Inspections issues approximately 300 audits and evaluations a year. The OIG Work Plan sets forth various projects, including OIG audits and evaluations, that are underway or planned to be addressed during the fiscal year and beyond. SunHawk's OIG Work Plan Summary Report for Providers, attached here, summarizes currently active Work Plan items and sorts relevant Work Plans items into Provider categories.

Click here to download the OIG Work Plan Summary Report for Providers

SunHawk’s team of experts are always available to offer their assistance. To stay apprised of the future reports subscribe to our newsletter and follow us on LinkedIn.

If additional information would make this report more valuable to you, please reach out and give us your thoughts.

Jan.Elezian@SunHawkConsulting.com
Jim@SunHawkConsulting.com

SunHawk Consulting is a team of highly skilled and experienced subject matter experts in the Healthcare, Life Sciences, and Insurance Industries who understand that the client’s needs come first. SunHawk provides Crisis Management Response, Compliance Consulting, Disputes & Investigations, and Staff Augmentation services for Boards of Directors, internal/external legal counsel, company management, special committees, and government agencies.

SunHawk's Payer Focused OIG Work Plan Update for March 2021

HHS OIG Office of Audit Services and Office of Evaluation and Inspections issues approximately 300 audits and evaluations a year. The OIG Work Plan sets forth various projects, including OIG audits and evaluations, that are underway or planned to be addressed during the fiscal year and beyond. SunHawk's OIG Work Plan Summary Report, attached here, summarizes currently active Payer-focused Work Plan items. Click here to download the OIG Work Plan Summary Report for Payers SunHawk’s team of experts are always available to offer their assistance. To stay apprised of the future reports subscribe to our newsletter and follow us on LinkedIn. If additional information would make this report more valuable to you, please reach out and give us your thoughts. Kimulet.Winzer@SunHawkConsulting.com James.Rose@SunHawkConsulting.com Jim@SunHawkConsulting.com About SunHawk Consulting SunHawk Consulting is a team of highly skilled and experienced subject matter experts in the Healthcare, Life Sciences, and Insurance Industries who understand that the client’s needs come first. SunHawk provides Crisis Management Response, Compliance Consulting, Disputes & Investigations, and Staff Augmentation services for Boards of Directors, internal/external legal counsel, company management, special committees, and government agencies.

Preparing for the Unthinkable: Fraud Risk Management in the Age of COVID-19

Since March 2020 when COVID-19 was determined to be a global pandemic, life as we know it has radically changed. Everyone has been significantly challenged, and sadly, more than two million people have died globally. Yet, how prepared were business organizations in anticipating something that had not been seen in 100 years? As part of thinking about the unthinkable, I wonder how many organizations prior to 2020 included in their fraud risk assessments the possibility of a global pandemic and the associated frauds that could occur. I would say very few, if any, included such a likelihood. Companies have lost millions of dollars to pandemic frauds. There have been personal protective equipment (“PPE”) scams with fraudsters offering non-existent or substandard masks, gloves, and other in-demand PPE. Fraudulent web domains, robocalls, emails, and texts have all been used to defraud businesses and individuals. The Association of Certified Fraud Examiners has issued a series of benchmarking studies on the impact of the pandemic on fraud occurrence, titled Fraud in the Wake of COVID-19.[i] The results are as expected. The respondents, representing organizations across all industries, observed a rise in fraud. The top five fraud schemes from the December 2020 study that showed an overall increase due to COVID-19 were cyberfraud (88% increase), payment fraud (82% increase), unemployment fraud (81% increase), fraud by vendors (80% increase), and healthcare fraud (79% increase).[ii] Fraud Risk Management is a Priority Had there been a better understanding of the fraud risk, organizations would have been better able to respond to and mitigate pandemic-related fraud, as well as other fraud schemes and scams affecting businesses. We will never eliminate fraud but implementing an effective anti-fraud program with appropriate fraud risk management can go a long way in protecting an organization. Fraud risk management is a component of an effective organizational ethics and compliance program. Included in an integrated approach is a fraud risk assessment. According to the Fraud Risk Management Guide, “A fraud risk assessment is a dynamic and iterative process for identifying and assessing fraud risks relevant to the organization."[iii] A fraud risk assessment analyzes and documents the risk of fraud within an organization. This includes the occurrence or potential for occurrence of the three main categories of fraud: asset misappropriation, corruption, and financial statement fraud. It also includes the numerous sub-categories of occupational fraud including billing schemes, payroll schemes, fictitious revenues, conflicts of interest, bid-rigging, kickbacks, bribery, and many others. Included in a comprehensive fraud risk assessment are the third parties who work on behalf of an organization, namely vendors, agents, representatives, and others. The assessment should contain the fraud risks related to geography, industry, products and services, mergers and acquisitions, customers who are government run or state-owned entities, and other risk factors. In every fraud risk assessment that I have performed for clients, previously unknown or little-considered fraud schemes were disclosed and addressed before they could become consequential events. For example, when conducting a compliance program assessment for a U.S. university system, I identified Foreign Corrupt Practices Act (“FCPA”) risk due to their business interactions in China. The university had minimal understanding of the FCPA with no policies or procedures to address that risk of bribery and corruption. In another fraud risk assessment that I conducted for a corporate entity, a formal fraud risk management program was recommended and implemented after the discovery of a long-running, multi-million-dollar fraud scheme perpetrated by a trusted manager in concert with an external party. A Fraud Risk Assessment is Fundamental According to A Resource Guide to the U.S. Foreign Corrupt Practices Act, Second Edition, “Assessment of risk is fundamental to developing a strong compliance program and is another factor DOJ and SEC evaluate when assessing a company’s compliance program.” The DOJ’s Evaluation of Corporate Compliance Programs, updated in June 2020, goes further by asking “What methodology has the company used to identify, analyze, and address the particular risks it faces,” and “Is the risk assessment current and subject to periodic review?” I contend that the risk of fraud is integral to an enterprise risk assessment. I further assert that if an organization fails to conduct ongoing fraud risk assessments, that organization does not have an effective compliance program. While pandemic related fraud may be a once in a lifetime occurrence, the multitude of other commonly occurring and damaging fraud schemes are not. They are ever-present and successful organizations incorporate periodic fraud risk assessments to protect from regulatory, financial, legal, and reputational risk. [i] Fraud in the Wake of COVID-19, Association of Certified Fraud Examiners, December 2020, https://www.acfe.com/covidreport.aspx [ii] Ibid. [iii] Fraud Risk Management Guide, Research Commissioned by the Committee of Sponsoring Organizations (COSO) of the Treadway Commission, September 2016. About Martin Biegelman Martin Biegelman, CFE, CCEP Managing Director SunHawk Consulting, LLC Martin.Biegelman@SunHawkConsulting.com Martin Biegelman has spent a lifetime detecting, investigating, and preventing fraud and corruption in various leadership roles in law enforcement, consulting, and the corporate sector. His work on behalf of corporate management and boards includes conducting internal investigations alleging fraud, corruption, Foreign Corrupt Practices Act violations, conflicts of interest, whistleblower retaliation, and other employee and vendor misconduct. Martin’s work also includes developing, assessing, and enhancing corporate compliance and ethics programs including internal investigative and anti-bribery compliance programs, as well as performing fraud risk assessments. Click Here to view Martin's full bio SunHawk Consulting, LLC and its compliance consultants and advisors are highly experienced in conducting fraud risk assessments for clients. Our subject matter experts can provide detailed insight into your specific risk profile and other compliance program needs. We are happy to have a discussion with you whether you have never conducted such an assessment or have not performed one recently.

Join SunHawk at the 25th Annual HCCA Compliance Institute

SunHawk is excited to announce that President, Jim Rough, Managing Director, James Rose, and Director, Kimulet Winzer, will be presenting at this year's HCCA Compliance Institute! To register for this event, click HERE! Ramping Up Virtual Project Management / Team Facilitation in Response to COVID-19? SunHawk Can Help! Our skilled leaders and professionals at SunHawk are experts at managing complex and time sensitive projects in a virtual on-line world. In these disruptive times, we can jump in to help your organization with regulatory and compliance management needs including: · Organizing a short-term crisis management/response team, · Facilitating or assuming leadership of a new compliance initiative, or · Providing leadership to an established team or adding additional expertise. Do you have work that needs to be done? Do you not have the immediate bandwidth or resources to see such projects to fruition given other priorities? We can help, please reach out to Jim Rough or Kimulet Winzer for assistance: Jim@SunHawkConsulting.com Kimulet.Winzer@SunHawkConsulting.com SunHawk Consulting is a team of highly skilled and experienced subject matter experts in the Healthcare, Life Sciences, and Insurance Industries who understand that the client’s needs and budgets come first. SunHawk provides Crisis Management Response, Compliance Consulting, Disputes & Investigations, and Staff Augmentation services for Boards of Directors, internal/external legal counsel, company management and employees, special committees, bankruptcy trustees and receivers, and government agencies.

NEW! SunHawk's Corporate Integrity Agreement (CIA) Summary Report - Life Science

The Corporate Integrity Agreement (CIA) Summary Report is here! The United States Government requires Corporate Integrity Agreements (CIA) for health care Providers, Payers and Life Science companies when settling allegations of false claims related to quality of care or corporate integrity issues, against various Federal health care programs. Under the terms of a CIA, companies agree to various obligations including, in most cases, the engagement of an Independent Review Organization. The CIA summaries, attached here, provide focused insights into healthcare related Corporate Integrity Agreements (CIA) settled over the last couple of years and are extracted from published CIAs and US Department of Justice press releases. Click here to download the Life Science Corporate Integrity Agreement (CIA) Summary SunHawk’s team of experts are always available to offer their assistance. To stay apprised of the future reports subscribe to our newsletter and follow us on LinkedIn. If additional information would make this report more valuable to you, please reach out and give us your thoughts. Martin.Biegelman@SunHawkConsulting.com James.Rose@SunHawkConsulting.com Jim@SunHawkConsulting.com SunHawk Consulting is a team of highly skilled and experienced subject matter experts in the Healthcare, Life Sciences, and Insurance Industries who understand that the client’s needs come first. SunHawk provides Crisis Management Response, Compliance Consulting, Disputes & Investigations, and Staff Augmentation services for Boards of Directors, internal/external legal counsel, company management, special committees, and government agencies.

SunHawk's Provider Focused HHS OIG Audit Summary Reports - February 2021 Update

HHS OIG Office of Audit Services and Office of Evaluation and Inspections issues approximately 300 audits and evaluations a year. The findings and recommendations provided herein are extracted from the specific audits included in this report and referenced by their respective report numbers at the end of each abstract. SunHawk’s report, attached here, summarizes completed audits and evaluations over the last 12 months and sorts relevant audits into the Provider category. Click on the graphic above to download the Provider-focused OIG Audit Summary Report SunHawk’s team of experts are always available to offer their assistance. To stay apprised of the future reports subscribe to our newsletter and follow us on LinkedIn. If additional information would make this report more valuable to you, please reach out and give us your thoughts. Jan.Elezian@SunHawkConsulting.com Jim@SunHawkConsulting.com SunHawk Consulting is a team of highly skilled and experienced subject matter experts in the Healthcare, Life Sciences, and Insurance Industries who understand that the client’s needs come first. SunHawk provides Crisis Management Response, Compliance Consulting, Disputes & Investigations, and Staff Augmentation services for Boards of Directors, internal/external legal counsel, company management, special committees, and government agencies.

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