The government has an increasing distrust of “paper” compliance programs — policies and procedures that look good on paper, but are not reflected in daily practice at the company and may not adequately detect or prevent misconduct. The good news is that compliance professionals have received two pieces of informative guidance in 2017 that help define and communicate the government’s expectations for an effective compliance program. The first, published by the Department of Justice (DOJ), lists “common questions” the DOJ asks when it evaluates a company’s compliance program as part of a criminal investigation. The second guidance reflects a meeting between the U.S. Department of Health and Human Services’ Office of Inspector General (OIG) and the Health Care Compliance Association (HCCA) and offers a list of strategies for measuring various compliance elements. Both documents are useful tools for life sciences and healthcare organizations seeking to design effective compliance programs, as well as those looking to validate and improve upon their existing compliance controls.
Insiders from Navigant — Matt Chandler, Christine Longawa, and Saul Helman — guide you through the two recent releases from the DOJ and OIG and share insights on compliance effectiveness best practice.