Which changes in accounting principle are material?
What misstatements or omissions are “material” and which are not? With the recent roll-out of the SEC’s new whistleblower regulations, it is a popular question among companies and prospective whistleblowers. This brief summary offers insights into this important topic as it applies to changes in accounting principle. First, despite recent IFRS rumblings, SEC regulations require […]
Confidentiality agreements blocked by SEC Rule 21F-17
For whistleblowers and their past or present employers, one of the more important features of the SEC’s new whistleblower program regulations is Rule 21F-17, copied in part below. Over the years, targets of whistleblower claims have employed increasingly aggressive and sophisticated tactics — including “gag orders,” TROs, and breach of confidentiality agreement or even trade-secret-theft […]
Sharing PHI with attorneys: OK under HIPAA?
The single largest group of health care whistleblowers are health care workers themselves — nurses, doctors, dentists, therapists and billing professionals — who encounter fraud on the job. Do such health care workers violate HIPAA by disclosing patient protected health information (“PHI”) when blowing the whistle? There is no need for them to do so. […]