Question
Assume you are a compliance program manager (and sole compliance professional) of a small public company, Elder Oasis, that operates and staffs several nursing homes
Assume you are a compliance program manager (and sole compliance professional) of a small public company, "Elder Oasis," that operates and staffs several nursing homes along the East Coast. They create and deploy several types of healthcare devices like stethoscopes, blood pressure monitors, and diabetes kits. All transmit data wirelessly to phones and computers and store that information in a proprietary phone application. Elder Oasis also has its own web-based records portal for health practitioners and their patients, the residents of the nursing facilities.
Elder Oasis is growing quickly and acquiring other homes, and since you seem to have a firm grasp on compliance, the CFO would potentially like to promote you to the position of Chief Compliance Officer. But first, she would like you to propose to her the structure you think the company should have for compliance.
She has asked you to draft an email to her and the Chief Legal Officer of Elder Oasis outlining the following:
- the employee you think you should report to and why, and
- if you think the company needs an official Compliance Committee.
If you believe that Elder Oasis does need a Compliance Committee, whom do you think the members should be, and how often should they meet? Note that the first question above refers to the actual person you report to (the person who gives you your performance review) rather than someone to whom you give a report on compliance.
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