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Improper inducements, kickbacks, and self-referrals Of course, every hospital will have different risk areas, and it is important to address these matters with specificity in a compliance program. Often, management can obtain some guidance from other hospitals; however, it is imperative that a hospital create a compliance program that is custom-tailored to its specific obligations. 3. Naming a Compliance Officer or Contact Person After assessing all risk areas and developing a compliance strategy, the next step is to designate a chief compliance officer, or several employees who will oversee ...

Washington, D.C. 20573 Dear Chairman Khouri, We write to express concern with the reported practices of certain vessel-operating common carriers (VOCCs) related to the denial of carriage for agricultural commodities.   If the reports are true, such practices would be unreasonable, anticompetitive, and hurt millions of producers across the nation.  We support the Federal Maritime Commission’s current efforts to investigate these reports, and call on the Commission to quickly resolve this critical issue. As you know, ports across the United States are experiencing unprecedented congestion ...