It found that, during the study period, 455 entities had revealed violations of 1,850 facilities and that the rate of disclosure had also gone up. The EPA also noted that the amnesty policy was most beneficial in four major areas. These were overall benefit to human health and the environment, prompt disclosure and correction of violations, improvements in corporate compliance policies and programs, and increased awareness of new environmental issues. The EPA took special note of how the policy encouraged prompt disclosure and correction of violations. Those who disclosed said that the program encouraged them to prove their auditing and reporting procedures. Most of them reported improving corporate programs in the form of a broader scope of corporate compliance activities; greater diligence, thoroughness and frequency of auditing processes; and greater timeliness of internal and external reporting of violations (Mustokoff et al.).
Antitrust Amnesty Program
Promulgated on August 10, 1993, this policy considered the DOJ's most successful amnesty program (Mustokoff et al. 2000). It draws its success from an absolute guarantee of amnesty from criminal prosecution for disclosing directors, officers and employees of the company. The disclosure is shielded from criminal liability if he is the first to report the violation; promptly and effectively ends the violation; reports the violation spontaneously and completely, and cooperates with Antitrust. The disclosure has to be a true corporate act rather than an isolated or individual act. The discloser makes appropriate restitution. He did not coerce another participant into the violation and is not its leader or instigator (Mustokoff et al.).
Before 1992, the DOJ held discretionary authority under the Antitrust Division's self-disclosure policy to exercise leniency, rather than amnesty, to a discloser (Mustokoff et al. 2000). In the 14 years of implementation, only 17 companies applied for leniency and only 10 were granted it. Under the present policy, leniency applications grew 12 times. The revenues accruing from enforcement activities exceeded $200 million in the first year alone. It evidenced that full amnesty would promote voluntary disclosure of antitrust activity. Besides generating enforcement revenues, amnesty agreements effectively put an end to the collusion. This immediately benefited the government by correcting the legal violation (Mustokoff et al.).
Responsive Healthcare Amnesty Model
Successful healthcare fraud enforcement can be effected, gleaning from these specific models (Mustokoff et al. 2000). They provide evidence that voluntary disclosure program will be effective if they offer some guarantee of amnesty to disclosers and on condition. It needs to be guided by clear, uniform and truly enforced standards. These models suggest that an effective voluntary disclosure program for healthcare providers could make the same guarantee of amnesty from civil liabilities and criminal prosecution and on certain conditions. The violation was discovered voluntarily and independently of auditing or whistle-blowing; was disclosed promptly; and came out of appropriate self-disclosure and in full cooperation with the OIG's investigation of the violation. The entity would also repay in full, including overpayments and interest, within the time set by the OIG and operate an OIG-approved compliance plan to prevent recurrence. The shared experiences of the government agencies involved in these proven self-disclosure amnesty programs may prove applicable to healthcare providers who will self-disclose. The correction of violations is perceived to produce considerable positive effects. One is that it will encourage prompt disclosure and correction of the violation. This will lead agents to go after the worst violators. By eliminating the risk, which would ordinarily accompany the act of disclosure, the development and use of more compliant programs can be enhanced. It can also identify types and perpetrators of abuse, increase enforcement revenues and decrease enforcement costs. Most of all, it will establish a desirable environment of greater cooperation and trust between the government and healthcare providers (Mustokoff et al.).
Physician's Self-Disclosure and Patient Satisfaction recent non-randomized study of surgeons found that their occasional self-disclosure made the patients perceive their warmth and friendliness and resulted in patient satisfaction (Beach et al. 2005). Physician self-disclosure may or may not conduce to trust and rapport. Some may even consider it inappropriate as it crosses professional boundaries between physician and patient. A study conducted on patient satisfaction involved 59 primary care physicians and 65 surgeons and audio-taped statements by patients who made 1,265 office visits. The patients were surveyed with questions on their overall satisfaction, whether they would recommend their doctor to others, how well he knew them and his qualities as a person. Other studies revealed the occurrence of...
Business Communication and the Workplace Different types of relationships Relationships can be personal or impersonal, they can take on a life of their own, and they can change when we least expect it. Successful or valuable relationships require proper coaching and maintenance. As much as we establish relationships with people such as family, neighbors, and friends and so on, we have noted that the experience of love is same the only thing
Methods for evaluating and monitoring the effectiveness of peer-assisted learning programs are discussed as well, followed by a summary of the literature review. Background and Overview. The growing body of scholarly evidence concerning peer tutoring has been consistent in emphasizing the powerful effects that children can exert on the academic and interpersonal development of their classmates and/or other students (Ehly & Topping, 1998). For example, Bloom (1984) reported early on that
Ethics in Group Counselling Ethics in Group Counseling Group Therapy Counselling: Ethics The ethical concerns of therapists have been getting larger in quantity and sophistication. Managed care demands professionals to think about problems with discretion as well as delivery associated with proficient treatment whilst other decisions might include informed consent, a variety of relationships together with customers, and ignoring discretion given clients' harmful conduct. These types of deliberations have been happening inside
S. were "proficient in reading and math," Pytel explains. These statistics "loudly states that students entering high school" are simply not prepared, Pytel goes on. Moreover, U.S. students do not fare well on the international educational stage. At a time when globalization has brought much closer linkage between cultures, economies, and countries, American school children are lagging behind. The justification for focusing on strategies to keep children interested in school
Relational Discourse in a Film of Your Choice Conceptual Framework Discussion Forms of relational development Primary factors draw predominantly from Knapp's version of relationships: utilizing "steps." Nevertheless, this text utilizes the concept of moving up/down-similar to a lift) (Khanna, 2010) Motion via the stages: • Motion usually systematic as well as sequential. Nevertheless, sequence has been interchangeable/fluid; a few stages might be neglected. • Motion might be onward-in the direction of higher intimacy if continuing
In many ways, students live both in the land-based or physical world as well as in the virtual world; leading what some considers parallel lives. Helliwell & Putman (2004) posit that social networking sites may offer an avenue for the development of greater social capital which may serve to further reinforce students' likelihood of integrating Facebook and other social media sites into their regular routines. A suggestion made as to the
Our semester plans gives you unlimited, unrestricted access to our entire library of resources —writing tools, guides, example essays, tutorials, class notes, and more.
Get Started Now