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CliftonLarsonAllen LLP. Start with desired results. Identify common behaviors that cut across multiple compliance areas and make those central to all compliance initiatives and daily business. An effective compliance and ethics program is essential for virtually all U.S. Essentially, a compliance and ethics program is a set of protocols a. What should be in a company’s anti-cartel compliance program? Although implementation details may vary among companies, we believe an effective program needs to cover each of these fundamental points. What Are the Essential Elements of a Corporate. What Are the Essential Elements of a Corporate Compliance. They have developed what they term the five essential elements of a corporate compliance program. While there is no 'one-size-fits-all' compliance program for every organization, there are several core components that must exist to have an effective Program. This QuickCounsel covers those components. September 3. 0, 2. Draft Compliance Program Guidance for Recipients of PHS Research Awards (7. Fed. 7. 13. 12; November 2. Supplemental Compliance Program Guidance for Hospitals (7. Fed. 4. 85. 8; January 3. Compliance Program Guidance for Pharmaceutical Manufacturers (6. Fed. 2. 37. 31; May 5, 2. 7 Steps to a Highly Effective IT Compliance Program Documenting internal policies and controls, assigning appropriate compliance management oversight, and ensuring compliance through training are three of the seven steps. Compliance Program Guidance for Ambulance Suppliers (6. Fed. 1. 42. 45; March 2. Compliance Program Guidance for Individual and Small Group Physician Practices (6. Fed. 5. 94. 34; October 5, 2. Compliance Program Guidance for Nursing Facilities (6. Fed. 1. 42. 89; March 1. Compliance Program Guidance for Medicare+Choice Organizations (6. Fed. 6. 18. 93; November 1. Compliance Program Guidance for Hospices (6. Fed. 5. 40. 31; October 5, 1. Compliance Program Guidance for the Durable Medical Equipment, Prosthetics, Orthotics, and Supply Industry (6. Fed. 3. 63. 68; July 6, 1. Compliance Program Guidance for Third- Party Medical Billing Companies (6. Fed. 7. 01. 38; December 1. Compliance Program Guidance for Clinical Laboratories (6. Fed. 4. 50. 76; August 2. Compliance Program Guidance for Home Health Agencies (6. Fed. 4. 24. 10; August 7, 1. Compliance Program Guidance for Hospitals (6. Fed. 8. 98. 7; February 2. Top. Return to Compliance. What Are the Essential Elements of a Corporate Compliance Program? Can you synthesize and reconcile the world's leading laws, regulations and commentaries on the best practices an anti- bribery and anti- corruption compliance program? I recently saw one such approach by Paul Mc. Nulty and Stephen Martin of the law firm, Baker and Mc. Kenzie. They have developed what they term the five essential elements of a corporate compliance program. These five elements are based upon the best practices as set out in the seven elements of a corporate compliance program under the US Sentencing Guidelines; the 1. Good Practices by the OECD on Internal Controls, Ethics, and Compliance; the FCPA Guidance's Ten Hallmarks of Effective Compliance Program and the UK Bribery Act's Six Principles of an Adequate Procedures compliance program. The five elements are: Leadership. Risk Assessment. Standards and Controls. Training and Communication. Oversight. I. There should be an unambiguous, visible and active commitment to compliance. But even more than support or the right tone, compliance standards require that companies must have high- ranking compliance officers with the authority and resources to manage the program on a day- to- day basis. And compliance officers must have the ear of those ultimately responsible for corporate conduct, including the board of directors. Some of the questions you might think about in connection with the leadership of your compliance program are the following: How is board oversight implemented? Is there an ethics or audit committee reporting to the full board? What is the role of the Chief Compliance Officer? What is the role of the General Counsel? How do the legal and compliance departments interact? Is she or he treated as a second- class citizen? Equally the Board of Directors has a key role to fulfill. The Board must ensure compliance policies, systems and procedures are in place and it should monitor implementation and effectiveness of the compliance program: Be actively involved. Attend Board meetings. Review, consider and evaluate information provided. Inquire further when presented with questionable circumstances or potential issues. Once Board knows of a potential compliance issue it must act. Regularly receive compliance briefings and training. II. Compliance issues can touch many areas of your business and you need to know not only what your highest risks are but where to marshal your efforts in moving forward. A risk assessment is designed to provide a big picture of your overall compliance obligations and then identify areas of high risk so that you can prioritize your resources to tackle these high risk areas first. What are some of the areas where you need to assess your risks? Country Risk - What is the correlation between growth markets and corruption risk and what is the perceived level of corruption? In other words, the Transparency International Corruption Perceptions Index or similar list. Sector Risk - Has government publicly stated industry is under scrutiny or already conducted investigations in sector? Are there corruption risks particular to the industry? Business Opportunity Risk - Is the business opportunity a high value project for your company? Are there multiple contractors or intermediaries involved in the bidding or contract execution phase? Business Partnership Risk - Does this business opportunity require a foreign government relationship? Does a foreign government require you to rely upon any third parties? Transaction Risk - Will your company be required to make any ? Are you required to use any intermediaries to obtain licenses and permits? In addition to an initial risk assessment to either (1) inform your compliance program or (2) help you to identify high risks and prioritize their remediation, risk assessments should be a regular, systemic part of compliance efforts rather than an occasional, ad hoc exercise cobbled together when convenient or after a crisis. They should be conducted at the same time every year and performed by a consistent group, such as your internal audit department or enterprise risk management team. Such annual risk assessments act as a strong preventive measure if they are performed before something goes wrong as it avoids a . Every company should have a Code of Conduct which should express its ethical principles. However, a Code of Conduct is not enough. Every company should have standards and policies in place that build upon the foundation of the Code of Conduct and articulate Code- based policies, which should cover such issues as bribery, corruption and accounting practices. Every Company should then ensure that enabling procedures are implemented to confirm those policies are implemented, followed and enforced. FCPA compliance best practices now require companies to have additional standards and controls, including, for example, detailed due diligence protocols for screening third- party business partners for criminal backgrounds, financial stability and improper associations with government agencies. Ultimately, the purpose of establishing effective standards and controls is to demonstrate that your compliance program is more than just words on a piece of paper. IV. Simply conducting training usually is not enough. Enforcement officials want to be certain the messages in the training actually get through to employees. The Department of Justice's (DOJ) expectations of effectiveness are measured by who a company trains, how the training is conducted and how often training occurs. There are several key elements to training. First is that you need to train the right people. You must prioritize which audience to educate by starting your training program in higher risk markets and focus on directors, officers and sales employees who may have direct contact with government officials or deal with state- owned entities. Again, focus initially on training country managers in your company's high- risk markets, then expand geographically and through the ranks of employees. Second, in high risk markets and for high risk employees or third parties you should conduct live, annual training. Enforcement officials have made it clear that live, in- person training is the preferred method in high- risk markets and also that it should be regular and frequent. Another benefit of live training is the immediate feedback from employees that would be much less likely to occur during a webinar or other remote training. Lastly, during live training, employees are more likely to make casual mention of a potentially risky practice, giving you the opportunity to address it before it becomes a larger problem. It is important that you pay attention to what employees say during training. This is because training can alert you to potential problems based on the type of questions employees ask and their level of receptiveness to certain concepts. For example, during training employees might ask specific questions about important compliance considerations such as their interactions with government officials or gift- giving practices. Such questions can raise red flags and uncover issues that should be reviewed and addressed quickly. V. Even after all the important ethical messages from management have been communicated to the appropriate audiences and key standards and controls are in place, there should still be a question of whether the company's employees are adhering to the compliance program. These ongoing efforts demonstrate your company is serious about compliance. Monitoring is a commitment to reviewing and detecting compliance programs in real time and then reacting quickly to remediate them. A primary goal of monitoring is to identify and address gaps in your program on a regular and consistent basis. Auditing is a more limited review that targets a specific business component, region or market sector during a particular timeframe in order to uncover and/or evaluate certain risks, particularly as seen in financial records. However, you should not assume that because your company conducts audits that it is effectively monitoring. A robust program should include separate functions for auditing and monitoring. While unique in protocol, however, the two functions are related and can operate in tandem. Finally, what are your remediation efforts? Your company should remediate problems quickly. A key concept behind the oversight element of compliance is that if a company is policing itself on compliance- related issues, the government will not have to do it for them. Remediation, then, is an important component of oversight. It is not enough to just gather information and identify compliance problems through monitoring and auditing. To fulfill this essential element of compliance, you also have to respond and fix the problems. I have found that the Baker 'Five Essentials' approach is an excellent way to think through your obligations under a wide variety of anti- corruption and anti- bribery requirements. It allows you to put in place a program which should meet virtually any legal requirements you may come up against by doing business anywhere in the world. Lastly, the five- step approach is an excellent way for you to benchmark your current compliance program. Visit the FCPA Compliance and Ethics Blog, hosted by Thomas Fox, for more commentary on FCPA compliance, indemnities and other forms of risk management for a worldwide energy practice, tax issues faced by multi- national US companies, insurance coverage issues and protection of trade secrets. This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Those high- risk employees who effectively manage their risk factors can lower their premiums over time. Alabama and Missouri are the only two states to effectively penalize high- health risk employees. Purpose of health policy or idea. In August 2. 00. 8, the Alabama State Employees Insurance Board (ASEIB) approved a plan that will link monthly premiums paid by state employees directly to their participation in wellness. The plan, a voluntary program called the Wellness Premium Discount Program, will provide state employees with access to a free health screening beginning in 2. Those employees identified. BMI), blood pressure, cholesterol, or blood sugar will then be given a voucher for a free consultation with a doctor. Those employees who don't take advantage of the. Alabama state employees currently pay no monthly health premium unless they are smokers, who pay $2. A $5. 0 monthly fee, with a $2. January 2. 01. 0. Only smokers who don't get screened will be required by default to pay the full $5. Main points. Main objectives. Alabama has among the highest rates of obesity, stroke, diabetes and hypertension in the U. S. The current plan aims to reduce the rate of chronic conditions among state employees and in doing so. State Employees Health Insurance Plan (SEHIP). ASEIB has argued, for instance, that health care costs for. BMI) are more than $1. BMI. Other research has shown that every dollar invested in wellness programs by. Type of incentives. The plan offers a financial incentive for state employees to identify and manage their risk(s) of potentially costly chronic health conditions, either by self management or through a doctor's. The structure of the program also suggests an incentive for the state to offer added wellness programs to its employees as a means of further reducing health risks and therefore health. Groups affected. Alabama state employees, Alabama state employees health insurance plan (SEHIP)This policy is a new take on an increasingly popular set of related policies, those that offer incentives to employees based on their participation in health promoting activites or adoption of. Consumers have tended to see such programs as punitive, however, even though plans promote them as incentive- based. The inclusion of BMI has made Alabama's current. Political and economic background. N/APurpose and process analysis. Current Process Stages. Origins of health policy idea. The plan was hatched by the Alabama State Employees Insurance Board and drew its inspiration from similar programs in other states. The program is also an expansion of SEHIP's existing Wellness. Program, which already offers worksite health screenings, flu vaccines, quarterly blood pressure screening, and reimbursement for participation in tobacco cessation programs. Other states- including Delaware, Kentucky, South Dakota- offer free health screenings and wellness or risk management programs to their state employees. Two states, Missouri and Arkansas, offer. Arkansas offers additional discounts to employees who are identified as being at very low risk of chronic conditions in. Prior to the current plan, Alabama itself had taken an initial step toward linking premiums to health behavior. In 2. 00. 4, the state first offered a health care premium discount to employees who. However, patient advocacy groups, particularly obesity advocates, have called the plan unfair and discriminatory. The academics offered at UAH can expand. Health & Wellness we have great resources available to assist students with their physical and mental. Explore key University of Alabama information including application requirements. Cooperative Education. Origins of health policy idea. The plan was hatched by the Alabama State Employees Insurance Board and drew its inspiration from similar programs in other states. The program is also an expansion of SEHIP's existing Wellness. Payroll Services; HR News; HR Forms. Wellness Program: Nye, Mary: 200026: Office of Disabil Serv-Accom. Honors Program; International Education. University Bookstore; Office of Academic Affairs; Research. UNIVERSITY OF SOUTH ALABAMA. 1-251-460-6101 MOBILE, ALABAMA 36688. UA’s University Medical Center Launches Wellness Walls for. Bachelor of Science in Nutrition: Wellness Option. Auburn University's degree option in Nutrition and Wellness is designed to prepare students for successful career entry into the broad health and wellness. Overweight employees themselves have also objected to the plan. William Ashmore, CEO of SEHIP has defended the plan in the national media. Wellness programs in other states are likewise relatively new, and therefore. Premium hikes for smokers, however, have been in place for a few years in several states, including Alabama. According to figures published online by ASEIB, Alabama predicted that the tobacco surcharge passed in 2. Instead, more than 2. The. following year (fiscal year 2. Expected outcome. William Ashmore, CEO of Alabama State Employees Health Insurance Plan (SEHIP), has stated that he expects that similar programs will be adopted by other states in the future; some academic experts. Others, however, predict that states may just wait to see how effective Alabama's program proves to be- -both in reducing health risks and generating health. Impact of this policy. The current incentive program has the potential to result in cost savings for the state health plan over the long- term, though the scale of such savings will depend in large part on employee. References. Sources of Information. Wolke, A and Sandoe, E. National Conference of State Legislatures, October 1. Health Policy Monitor, November 2. Available at http: //www. Special needs programs in Kuala Lumpur,Malaysia school for kids with autism,ADHD,dyslexia. Kits. 4Kids Foundation (Malaysia): Kits. Kids Foundation in Kuala Lumpur, Malaysia offers early intervention programmes for children with special needs and mainstream children, catering to their individual development and growth. Kits. 4Kids is both a MOE and MCYS registered special school / kindergarten for children aged 1. 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Junior Course of Study is designed to be self- paced for the student yet competencies are societal benchmarked for authentic independence at school, work or home. K4. K CARE program - Vocational track: The K4. K CARE Course of Study is a unique course of study where a student with moderate or severe disabilities may complete to graduate with a Kits. Kids Certificate of Achievement. The K4. K CARE Course of Study is an outgrowth of Kits. Kids Foundation Education Systems (EIPIC / Integrated Kindergarten / Junior program / Senior program / College). The following is a description of the CARE Course of Study. The CARE Course of Study is intended to meet the needs of a small group of students with disabilities who need a greatly modified curriculum that focuses on life- skills and post- school employment and independent living. 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The shield’s shape could be any of a number of variations of an oblong form (see image below). The shield board was comprised of solid wood or vertical planks, covered in hide. The hide protected the wood from warping in the rain, and it prevented splintering when struck in battle. Round shields were often used by cavalrymen. Attached to the center of the shield face was the boss. This hollow object provided room for the user to hold the horizontal metal or wooden hand- grip. The boss protected the hand and could be used offensively to punch the enemy. A wooden boss was often covered on the front by an iron plate. A typically all- metal boss was made of iron. It appeared as a hemisphere with circular flange or as an oblong shape with butterfly wing- shaped flange. ARCHAEOLOGICAL EXAMPLESThe celtic shield was primarily made of organic materials, wood and hide. As a result, direct archaeological evidence is very limited. Ian Stead composed a list of all known shield parts found in Britain. Here is a listing of major finds from across Europe: Witham Shield 4. BC (fig. A)Discovered in 1. River Witham, near the village of Washingborough, which is outside the city of Lincoln. Currently housed in the British Museum. This is not the whole shield, rather it is a thin bronze sheet which was mounted on a wood backing. A leather stylized boar once was once riveted to the face. The central boss was decorated with pieces of Mediterranean coral. The delicate nature of this shield indicates that it was not meant for battle. B)Discovered in 1. Chertsey, Surrey, England. Currently housed in the British Museum. Length: 8. 3. 6 cm, Width: 4. Weight: 2. 7. 5 kg. The body of the shield is made entirely of bronze. The handle is made of ash. C)Discovered in the River Thames at Battersea Bridge, London, England. Currently housed in the British Museum. This is a facing of multiple sheets of broze that were riveted to a now rotted shield- board. Decorated with glass inlay. As with the Witham and Chertsey shields this apparently was a ceremonial, rather than battle shield. D)Discovered in a bog on the island of Als, near Hjortspring farm. The site is on the modern border of Germany and Denmark. Remains of up to 8. These shields appear to be an offering of captured enemy equipment originating from the western Baltic. Although these objects did not come from a Celtic area, the shields and weapons found here display an influence of Celtic technology. The wooden shields were preserved by the anaerobic conditions of the bog. All are similarly shaped. They are rectangular in a range of proportions, all with shallow curved sides and corners. Length: varies among the shields from 6. Width: 2. 2 - 5. 2 cm. The largest shield is 8. The smallest is 6. The shields are thickest at the middle, in most cases 1 - 1. The edges get thinner at . The majority of the shield boards were carved from a single piece of wood. Others were formed of 2 or (more rarely 3) planks glued together with resin (sometimes with the addition of tennons). Any of the armor listed on this page can be worn without incurring a non-proficiency penalty if a character has the Heavy Armor Proficiency feat. Beginning as a small time supplier to the british armed forces, Windlass Steelcrafts today offers several services including military supplies, custom manufacturing. This section contains bugs related to Leather Armor (Skyrim). Before adding a bug to this list, consider the following: Please reload an old save to confirm if the. The shield bosses are of wood. They are mostly alder and lime, but some are harder woods. It is not known if they originally had a hide or cloth covering. E)In 1. 98. 8 the British Museum acquired a collection of 2. The longest shield is 8. At their purchase the shields were unprovenanced. However, the detective work of arcaheologist, Ian Stead, has since confirmed that these are indeed from a hoarde in Salisbury, England. These objects were probably votive offerings to the gods. These miniatures seem to realistically represent shields of actual use. As evidence of this, their form matches the shape of a near complete set of bronze edge bindings found at Spettisbury, Wilford Down and in a burial at Mill Hill, Deal. F)Fragments of three oak plank Celtic shields were discovered at the lake at La T. The find was made in the late 1. The now dissintigrated shield remains are housed in the Neuch. When found, they were roughly 1. All three were made of oak. Two of the three had a wooden boss. The third shield’s boss was missing. The shield board is made of thin sheets of wood, covered on the face and back in leather. The edging is also leather. The umbo is wood, covered in leather. It is now held in the National Museum of Ireland, Dublin. The designs were probably painted or attached as separate pieces of leather or metal. The shield found at Mill Hill, Deal, UK was accompanied my small metal decorations, which would have been mounted to the shield board.(Parfitt) Various animal decorations made of sheet bronze were found at Tintignac, a religious site in ancient Gaul. These included 2 boar heads, 1 horse head, and some detached legs of an identified animal. They are thought to be meant as the top to a military standard, but they may also have been intended to decorate a shield. One might expect these sculpted designs to be accurate representations, as they could have been based on captured arms and equipment. However, the designs do not mesh well with the Celtic La T. The image below illustrates a few. German shield blazons have not been recorded well at all. The Roman representations that have survived (Column of Marcus Aurelius, coinage, sarcophagi, etc.) are very obviously impressionistic depictions of generic . Connolly, Peter, Greece and Rome at War. Greenhill Books, 1. Cunliffe, Barry, The Ancient Celts. Green, Miranda, Celtic Art. Sterling Publishing Company, New York, 1. James, Simon and Rigby, V., Britain and the Celtic Iron Age The British Museum Press, London, 1. Discovery at Tintignac (web)6. A New History of Ireland. Oxford University Press. Iron Age Burials, from Mill Hill, Deal British museum Press, London 1. Publisher: Philipps- Universit. Rosenberg, Gustav; Knud Jessen, Fr. Johannessen, Hjortspringfundet, Volume 3, Issue 1, With English Summary, K. Stead, I. M., The Battersea Shield The British Museum Press, London, 1. Flector Patch (Diclofenac Epolamine Topical Patch) Drug Information: Warnings and Precautions. Cardiovascular Thrombotic Events. Clinical trials of several COX- 2 selective and. NSAIDs of up to three years duration have shown an increased risk. CV) thrombotic events, including myocardial. 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CATEGORY: Analgesic, Narcotic, General Anesthetic BRAND NAMES: Actiq A major concern with the prescribing of opioids is to ensure that they are used to treat pain and not abused for the euphoric effect that some people get when they take them. The Federal government demands that physicians who. Fentanyl is a schedule II narcotic approximately 100 times more potent than morphine. With IV administration, onset of the drug occurs rapidly, within 2 minutes, and is characterized by analgesia, sedation, and some ataxia. Duragesic is the brand name version of fentanyl. It is available as a transdermal patch, which is used to help. CV thrombotic events is similar for all NSAIDs. The. relative increase in serious CV thrombotic events over baseline conferred by. NSAID use appears to be similar in those with and without known CV disease or. CV disease. However, patients with known CV disease or risk. CV thrombotic events. Some observational studies found that. 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