Episodes

By Adam Turteltaub Healthcare is often rife with fraud, and organizations struggle to prevent it. To gain a different perspective on how to prevent wrongdoing, we spoke with Alec Burlakoff, a convicted fraudster from Insys Pharmaceuticals who now leads Limitless! Consulting. To prevent fraud, he recommends seriously looking at the incentives program in your organization, especially if there are individuals whose commissions may make up more than half of their compensation. Such high rates of re...

By Adam Turteltaub Are your helpline calls being responded to properly? Are the investigations proceeding expeditiously and properly? To find out, it’s good to do an audit periodically. Before you can begin, though, you need to determine if there is enough available data for an audit, cautions Juliette Gust, President of Ethics Suite, and author of the chapter “Auditing the Confidential Reporting Hotline and Case Management Program Effectives” in the new edition of The Complete Compliance and E...

By Adam Turteltaub Think you don’t have to worry about the SEC because you’re at a private company or a non-profit? Think again says, Kevin Muhlendorf, attorney at Wiley Rein. You may still end up in the Commission’s crosshairs. He warns that the SEC’s power of investigations expands far and wide, and just being a supplier to a publicly-traded company may lead them to focus on your business. If a private company is acquired by a public one or makes even a non-public offering, there is risk of f...

By Adam Turteltaub Business transformations can be times both of risk and opportunity for compliance programs. Employees, struggling to understand the changes around them and feeling stressed, may opt to do the wrong or at least ill-advised things. By the same token, transformations provide an opportunity for compliance teams to change their roles within the organization and redefine the value that they bring. Jill Swain, Global Ethics Manager and Dawn Wood, Engagement, Training and Programme M...

By Adam Turteltaub Oh, Artificial Intelligence. So much promise, and so much risk. What’s a compliance and ethics professional to do? Start by listening to this podcast about the chapter “Managing the Ethics and Compliance Risks of Artificial Intelligence” in the 2025 edition of The Complete Compliance & Ethics Manual. We spoke with the article’s co-authors, Gwen Hassan (chief compliance officer at Unisys), Dr. Anthony J. Rhem (CEO and principal consultant at A.J. Rhem & Associates), and Patric...

By Adam Turteltaub Sometimes you make a few technical changes to a compliance program because a law or regulation has changed. Autoliv didn’t want to do that and just meet technical requirement of the EU Whistleblower Directive. They wanted to use it as an opportunity to assess what they were doing to encourage employee reporting, whether it was working, and to improve support for people speaking up. Erica Wikman, Vice President, Corporate Compliance, Autoliv and David Barr (LinkedIn), co-found...

By Adam Turteltaub So the IT folk can’t wait for your business people to delete those old documents, meantime, the business people want to hold onto them because they never know when they might need that info again. Then, all of a sudden there’s a legal issue and a hold is in place. Instantly the game changes. Chris Kruse, Executive Vice President & Advisor at CasePoint explains that when a legal hold is placed several things need to happen: Employees with relevant need to be identified They ...

By Adam Turteltaub You do all that work but how do you know you’re being successful? It’s not like people come running in the door and say, “Hey, guess what bad thing I almost did.” The compliance team at the National Security Agency (NSA) had that same challenge. In this podcast, Natalie Knowles, Director of Compliance, and Zack Conyne, Manager, first provide an overview of the NSA. As they explain it has two primary missions: cybersecurity and signals intelligence. Every employee there annual...

By Adam Turteltaub When we last spoke with Tyler Shultz back in 2020, he discussed his experience at Theranos as both an employee and a whistleblower. Four years later, the case is in the rearview mirror, the former CEO is in prison, he founded two startups of his own, and he now speaks to corporations about cultivating courageous work cultures With the benefit of some time and distance, he shares in this podcast his experiences and what he has learned, particularly about corporate culture. The...

By Adam Turteltaub Few things hold more promise, or cause more stress for compliance professionals, than AI. What is it? How does it work? And does anyone know how to keep it from showing so much bias? David Silva, Chief Compliance Officer at Collaborative Imaging, will be addressing the topic of “Healthcare, Artificial Intelligence, and Compliance” at the 2025 HCCA Compliance Institute, which will takes place April 28-May 1 in Las Vegas. To get some of his insights now, we sat down for this po...

By Adam Turteltaub Chart auditing may not be the sexiest part of healthcare compliance, but it plays an important role in discouraging Medicare fraud and catching problems early. Madhavi Perumpalath, Director-Physician Practice Compliance at Northeast Georgia Health System and Alka Kumar, Compliance Director and Privacy Officer at Resolve Pain Solutions, explain that CMS provides good guidance to healthcare providers, such as diagnosis and procedure codes that are appropriate to bill for. Take ...

By Adam Turteltaub With value-based care growing, what role does compliance play? To find out we spoke with Carolyn Barton, Vice President, West Regional Compliance Officer at Kaiser Permanente. She explains that at Kaiser they define value-based care as a healthcare delivery and financing model that improves health outcome and increases access to affordable care in the community through evidence-based care, a commitment to equity and simplicity and aligned incentives. Doctors and health plans,...

By Adam Turteltaub No one would dispute that stress and compliance go hand in hand, but Scot Eibel (LinkedIn), a former chief compliance officer and currently leading Eibel Coaching and Compliance Consulting, warns that doesn’t mean it has to get out of control. There are steps we can all take to manage our stress levels. One stressor to watch for is over vigilance. While we all need to be vigilant, assessing risk and watching out for threats, it needs to be tempered. Resist the temptation, he ...

By Adam Turteltaub Benjamin Christenson, Trial Attorney and Special Assistant to the Director for Criminal Enforcement at the US Department of Justice Antitrust Division, joins us for this podcast in which he sheds light on the their document, Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations (ECCP). First issued in 2019, the ECCP was updated in 2024 to reflect changes in business, the law and technology, as well as what the Antitrust Division had learned over the ...

By Adam Turteltaub Want to improve your code of conduct? Don’t miss the session: Cornering the Code: A Multi-Disciplinary Approach Toward a Better Code of Ethics at the 2025 SCCE European Compliance & Ethics Institute. In this podcast Matej Drascek, Head of Internal Audit at LON d.d. and Ursula Schmidt of Schmidt Advisory recommend starting with the right language. Research has shown, they explain, that people react more strongly to words like “we” and “our”, which can convey a stronger sense o...

By Adam Turteltaub I want to write enough about this podcast to get you to listen to it, but not too much because then you might decide that reading this was enough. I’m conflicted, and conflicts of interest are the topic of this podcast with Kasturi Venkatesh, who spoke on the topic “Ethics in Action: A Fun Guide to Tackling Personal Conflicts of Interest” at the 2024 SCCE Compliance & Ethics Institute. When it comes to managing the issue, she explains, the primary goal for compliance teams i...

By Adam Turteltaub On November 6, 2024, the U.K.’s Home Office issued Economic Crime and Corporate Transparency Act 2023: Guidance to organisations on the offence of failure to prevent fraud (the Guidance). It comes out of the Economic Crime and Corporate Transparency Act (ECCTA), which establishes that a corporation can be held criminally liable for failing to prevent fraud committed by any “associated person” for the benefit of the company. This “associated person” can be an employee or even a...

By Adam Turteltaub Auditing and monitoring of the compliance program is pretty standard these days. Entain’s Karen Nightingale, Group Director of Ethics & Compliance and Jonathan Fox, Group Head of Ethics & Compliance Programmes, make the case in this podcast for going to the next level and actively testing your program. The two will also be addressing the topic at the 2025 SCCE European Compliance & Ethics Institute, which will take place in Lisbon, 10-12 March. Doing so, they suggest, can tur...

By Adam Turteltaub Note: This podcast was recorded on December 17, 2024. Any changes made after this date will be addressed at the Compliance Institute. At the 2025 HCCA Compliance Institute in Las Vegas, Adam Greene (LinkedIn), partner at Davis Wright Tremaine LLP will be leading the session “New Developments in Health information Privacy.” In this podcast he provides an overview of what he sees as notable privacy compliance challenges and what compliance teams need to be doing. Starting with ...

By Adam Turteltaub Well, it turns out that you can be in two places at once, if you are a surgeon. Even better, you can bill the government under the Medicare program for being at both of them. It’s not quite as strange as it sounds, explains Sara Brinkmann, Partner, and Lauren Gennett, Counsel, of King & Spalding, and, of course, there are rules. Overlapping surgeries occur when one attending surgeon is responsible for procedures that overlap in time. The attending may perform the critical pa...

By Adam Turteltaub On November 22, 2024, Principal Deputy Assistant Attorney General Nicole Argentieri recapped the changes made during the Biden Administration in enforcement policies and announced a few new ones. To better understand what this all means, we spoke with Daniel Kahn (LinkedIn) , partner at Davis Polk, and himself a veteran of the DOJ. There were a number of meaningful changes during the last few years, he noted. Most notably the voluntary disclosure program was significantly exp...

By Adam Turteltaub Once again it is time to sit down with Matt Kelly (LinkedIn), Editor and CEO at Radical Compliance and discuss what happened last year and where the compliance profession is going in the new one. In this podcast we looked back at 2024 and explored five key topics. Changes from the DOJ The DOJ recently issued a recap of its key activities over the last year or so, and Matt notes that a key change has been an increased willingness to give credit to companies that work with th...

By Adam Turteltaub Retaliation is the bane of every compliance program, with the potential of destroying employee confidence in reporting systems, not to mention embarrassing and expensive lawsuits. It is also complex and can be subtle, explains Keith Read, a former chief ethics and compliance officer and author of the book The Unconventional Compliance Officer: Doing Things Differently. There is overt retaliation, such as firing an employee for blowing the whistle. But there is also softer, mo...

By Adam Turteltaub How do you know your compliance program is working, both for your peace of mind or if the government comes knocking? It’s a tough question, and many wonder either how to start measuring or if they’re measuring the right thing. Andrew McBride, Founder & Chief Executive Officer at Integrity Bridge, has a great deal of experience in this area from his time serving as Chief Compliance Officer at Albemarle. In the wake of an FCPA scandal, the company had to be able to demonstrate ...