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From The CriticsReviewer: Catherine J. Buck, RN, MSN (Froedtert Hospital)
Description: This useful reference is created to assist organizations with understanding the Intermediate Sanctions Law. It has been designed in a checklist format that enables users to review an organization's activities and transactions and document findings related to level of compliance with the law.
Purpose: The purpose is to help leaders of affected organizations understand the new law. This book contains tools to assist in reviewing transactions and assessing relevant party and management exposure to intermediate sanctions. The material is presented in a workbook-like format with distinct sections easily identified by tabs. The useful charts and tools are included in hard copy as well as on disk. Step-by-step instructions on how to apply the information in assessing an organization's compliance are concise. The product clearly meets the stated objectives, and the authors provide a much needed reference.
Audience: This publication is intended for use by leaders of tax exempt organizations to help them insure compliance with the law as well as an aid in protecting their leadership from unwarranted liability. In my judgment, this product would be very useful for corporate compliance officers and staff. The authors are clearly authorities on the subject matter.
Features: With this comprehensive publication the authors suggest a specific approach to assessing organizational compliance with the Intermediate Sanctions Law. More specifically, they cover the identification of disqualified persons, examination of transactions between organizations and disqualified persons, manager liability, revenue sharing transactions, and rebuttable presumption of reasonableness. The product performance is excellent. The charts and tools are vital to the successful application of the material. The simplicity and organization of material is the highlight of the publication.
Assessment: This publication is a superb reference on a complex subject matter. Though I am not aware of other publications on this specific topic, it is far superior to traditional interpretive guidelines, often the only references available for new legislation. The authors do an outstanding job of assuring that nothing is lost in translation.