Colombia Update: COMPLIANCE – DUE DATE FOR THE IMPLEMENTATION OF SICOF (Corruption, Opacity and Fraud Risk Management Subsystem)

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.

By LLOREDA CAMACHO & CO, Colombia, a Transatlantic Law International Affiliated Firm.  

For further information or for any assistance please contact colombia@transatlanticlaw.com 

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