Compliance Leaders Offer Sound Advice at Orlando Health Care Forum

ORLANDO, Fla. (May 4, 2017) – The risks to Florida health care providers from enforcement activity is at an all-time high. But, how do providers develop and maintain a culture of compliance? It starts at the top, according to attorneys at Broad and Cassel.

During the firm’s Third Annual Orlando Health Care Forum, attorneys from the Health Law Practice Group alongside local and national leaders in healthcare compliance discussed board responsibility as well as board and executive leadership strategies and pitfalls.

“Our organizations are under threat from the government, whistleblowers and payers,” said Partner Michael Bittman, co-chair of the Health Law Practice Group, in his opening remarks. “There is a huge effort under foot to hold organizations and their executives accountable. The government is taking the position that the way to change corporate culture is through individuals.”

The forum kicked off with a fireside chat between Managing Partner Gabriel Imperato and Cigna Corporation’s Chief Compliance Officer Thomas F. O’Neil III discussing the board’s responsibility in compliance oversight.

“At the end of the day, if leaders aren’t assessing risks, you’re really vulnerable,” said O’Neil. He further noted the importance of transparency by management, embracing integrity and ensuring the board has the tools and information it needs to be effective.

During a panel discussion on board strategies and pitfalls, Withum Senior Policy Advisor Al Gutierrez commented that compliance officers are the corporate citizens for the organization and need to hold that attitude personally. He also suggested compliance officers engage more in scenario-based planning to prepare for an event.

“The whistleblower risk is so acute in the health care industry, you ignore any report of noncompliance at significant risk,” said Imperato. “Even an innocuous report can become a nightmare for an organization.”

The Health Forum concluded with a panel on health plan overpayments. Panelists included Michael Bittman, Michelle J. d’Arcambal of d’Arcambal Ousley & Cuyler Burke, and Jeanmarie Loria of Advize Health. Panelists reviewed pre-litigation considerations as well as litigation strategies and pitfalls tied to overpayments. “Don’t wait for an audit. Audit yourself,” said Loria.

Bittman went on to say, “Compliance must start at the top and permeate the organization. The delivery of a problem early is good news. The delivery of a problem late is very bad news.”

Broad and Cassel will host its seventh annual South Florida Health Forum in Fort Lauderdale this fall. The statewide law firm has built one of the most experienced and diversified Health Law Groups in the Southeastern United States. The firm has more lawyers certified in Health Law by the Florida Bar Board of Legal Specialization & Education than any other firm. Several of the firm’s health lawyers are certified by the Health Care Compliance Association in Health Care Compliance and are Certified Dispute Resolvers with the American Health Lawyers Association. Broad and Cassel’s health lawyers are widely published and frequently make presentations at leading educational programs throughout the country. Information on the firm’s health law events and industry and attorney news can be found on Broad and Cassel’s Health Law Blog at or on Twitter at

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