Are ethics programs no longer optional but mandatory? If the program is not good enough, is that fact itself the basis for liability?
The Perils of an Ineffective Compliance Program
Are ethics programs no longer optional but mandatory? If the program is not good enough, is that fact itself the basis for liability? A recent civil case filed by the creative health care prosecutors in the U.S. Attorney's Office in Philadelphia asserts that a company's "ineffective" compliance program satisfies the scienter requirements of the civil False Claims Act (FCA).
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