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https://www.mhhealthsearch.com/2011/12/08/the-responsible-corporate-officer-doctrine-how-will-it-affect-healthcare-executives/#:~:text=Posted%20December%208%2C%202011%20A%20U.S.%20legal%20doctrine,in%20the%20past%2C%20defendants%20have%20received%20only%20probation.
https://www.wnj.com/publications/the-responsible-corporate-officer-doctrine-findi
The commissioner’s statements are consistent with new guidelines issued by the FDA in January 2011. They indicate that the RCO doctrine is a valuable enforcement tool, permitting a responsible corporate officer to “be held liable for a first-time misdemeanor (and possible subsequent felony) under the [FDCA] without proof that the corporate official acted …
https://www.compliance.com/resources/the-new-oig-responsible-corporate-officer-doctrine/
https://www.kelleydrye.com/News-Events/Publications/Articles/Responsible-Corporate-Officer-Doctrine-Strict-Cr
Four corporate officers pled guilty in 2011 in the District Court for the Eastern District of Pennsylvania and received sentences ranging from six to nine months and given fines of $100,000 each. As part of their pleas, the executives accepted responsibility for the company's crime of running unauthorized clinical trials and for engaging in off-label marketing.
https://corpgov.law.harvard.edu/2017/07/05/the-responsible-corporate-officer-doctrine-survives-to-perplex-corporate-boards/
https://www.fdli.org/2018/11/the-responsible-corporate-officer-doctrine-protections-are-needed-despite-dojs-cautious-approach/
https://blog.volkovlaw.com/2011/12/the-responsible-corporate-officer/
The Responsible Corporate Officer by Michael Volkov · December 9, 2011 Prosecutors are under the gun – and rightfully so. Whether they have engaged in deliberate misconduct or just plain sloppy, there is no excuse for their recent conduct. What is equally troubling is how prosecutors are stretching the law to achieve unfair results.
https://www.maglaw.com/media/publications/articles/2011-02-14-revival-of-the-responsible-corporate-officer-doctrine/_res/id=Attachments/index=0/070021128Morvillo.pdf
ecution: the responsible corporate officer (Rco) doctrine, which provides that corporate officers may be held criminally liable for certain offenses relating to public health and welfare, even if the individual officers neither knew of nor participated in the unlawful activity in question. 2 Under the Rco
https://www.dbllaw.com/hhs-uses-responsible-officer-doctrine/
HHS Uses Responsible Corporate Officer Doctrine to Exclude Executives from Medicare/Medicaid February 15, 2011 James Dietz A recent decision by a federal district court in Washington D.C. serves as a warning to executives of healthcare-related corporations to be vigilant against healthcare fraud within their own businesses, or face personal, career-ending …
https://www.skadden.com/-/media/files/publications/2018/12/theresponsiblecorporateofficerdoctrineprotectionsa.pdf
Protections are Needed Despite DOJ's Cautious Approach. by John T. Bentivoglio, Jennifer L. Bragg, Maya P. Florence, and Sydney P. Sgambato. T. he responsible corporate officer (RCO) doctrine— which allows for criminal prosecution and impris- onment of an individual who was not personally involved in or aware of corporate misconduct—has been the subject of …
http://compliance.com/wp-content/uploads/2011/01/JHCC_01-11_Herrmann1.pdf
Journal of Health Care Compliance — January – February 2011 49 Exclusion principals in small health care companies, such as pharmacies and durable medical equipment companies. The OIG, however, recently announced a new focus on hold-ing owners, offi cers, and managing em-ployees personally accountable for corpo-rate wrongdoing.
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