COMPLIANCE – DUE DATE FOR THE IMPLEMENTATION OF SICOF –
September 17, 2022, is the deadline for obliged entities to implement SICOF (Corruption, Opacity and Fraud Risk Management Subsystem) pursuant to External Circular N°20211700000005-5 of 2021 of the National Superintendence of Health (“the “External Circular”).
OBLIGED ENTITIES TO IMPLEMENT SICOF:
Health Promoting Entities (EPS) of contributory, subsidized, special and exception regimes, Prepaid Medicine Companies (EMP), Prepaid Ambulance Services (SAP), Territorial Entities (ET), Special Patient Transport Service (SETP), public, private and mixed Health Services Providers Institutions (IPS).
POTENTIAL SANCTIONS:
Obliged entities that do not implement and comply the External Circular, might face the opening of an administrative investigation by the National Superintendence of Health, which could end-up with the imposition of fines starting on 800 Legal Monthly Minimum Wages, and up to 2.000 Legal Monthly Minimum Wages for legal representatives and other individuals responsible for SICOF.
If you require our support in order to guarantee the full compliance of these obligations, please do not hesitate to contact our Corporate and Compliance Law team.
Authors: Katerine Delgado I kdelgado@lloredacamacho.com I Derecho Corporativo / Nahara Mena I nmena@lloredacamacho.com I Derecho Corporativo