CHC Study Guide

CHC Study Guide Federal Sentencing Guidelines - Culpability Score Aggravating Factors =====1. upper-level employee participates, condones, or ignores offense 2. repeat offense 3. hinder investigation 4. awareness and tolerance of violation is pervasive Federal Sentencing Guidelines - Culpability Score Mitigating Factors =====1. effective compliance program 2. reported promptly 3. cooperation with investigation 4. accept responsibility Federal Sentencing Guidelines - Seven Elements of an Effective Compliance Program =====1. written standards of conduct 2. Chief Compliance Officer 3. effective education and training 4. audits and evaluations to monitor compliance 5. reporting processes and procedures for complaints 6. appropriate disciplinary mechanisms 7. investigation and remediation of systematic problems The only thing worse than not having a policy is... =====...having a policy and not following it.