On September 9, 2015, Sally Quillar Yates, Deputy Attorney General of the Department of Justice (DOJ) issued a memo entitled “Individual Accountability for Corporate Wrongdoing” to address the issue of incentivizing executives, as individuals, to follow appropriate compliance protocols by emphasizing potential individual liability.

The memo stresses the importance and the difficulty of enforcing personal liability on corporations for criminal and civil violations. I believe this is especially appropriate to the “larger” entities and integrated delivery systems involved in healthcare, because private practice providers have always been more directly confronted with the personal liability issues.

The memo outlines six steps to be taken in the coordination of civil and criminal investigations, most of which you would assume would already occur. However, the memo enforces and emphasizes the importance of the process.

The six steps outlined in the memo can be reviewed in the attached link.