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OIG Speakers emphasize the need for an active compliance plan in all practices

The Affordable Care Act (ACA) authorized the Secretary of the Department of Health and Human Services (HHS) to mandate that physicians who treat Medicare and Medicaid beneficiaries establish a compliance program. As of this date the Secretary has not issued a regulation making this mandatory. However, the HHS Office of Inspector General (OIG) has issued […]


SEC expands “testing the waters” rules

On September 26, the SEC adopted new rules that will allow all companies, regardless of size or reporting status, to use “testing the waters” communications. Under the new rules, any issuer or any person authorized to act on the issuer’s behalf will be able engage in oral or written communications to qualified institutional buyers and […]


Key Takeaways from New Overtime Rules Effective Jan 1, 2020

On Tuesday, the U.S. Department of Labor finalized its rule regarding the salary thresholds for the Fair Labor Standards Act’s overtime exemptions for so-called “white collar” workers. The FLSA requires that American employees receive minimum wage and overtime pay, unless they are subject to one of the law’s exemptions. The overtime exemptions for executive, administrative, […]


SEC Changes No-Action Process for Shareholder Proposals

On September 6, the SEC announced a change in its process for responding to no-action requests regarding shareholder proposals. In the past, a company seeking to exclude a shareholder proposal could submit a no-action request stating the basis for exclusion, and the SEC would respond in writing indicating whether or not it agreed with the […]


A busy week for the SEC and the Business Roundtable

The week of August 19 was a very busy one on two fronts. First, on August 19, the Business Roundtable issued a Statement on the Purpose of the Corporation, signed by the CEOs of 181 major American companies, saying that the purpose of the corporation is to act in the interests of all its stakeholders, […]








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