Both the Department of Justice and the Department of Health and Human Services Inspector General have long urged (and in many cases, mandated through settlements that include Corporate Integrity Agreements and through court judgments) that health care organizations have “top-down” compliance programs with vigorous board of directors implementation and oversight. Governmental reach only increased with
Corporate Integrity Agreements
OIG Pharmaceutical Compliance Roundtable Offers Insights into Effective Compliance Practices
By Kathleen A. Peterson on
Posted in HEAL®: Employment and Labor
On March 26, 2012, the U.S. Department of Health & Human Services Office of Inspector General (the “OIG”) published a report summarizing a February 23, 2012roundtable meeting between the OIG and compliance professionals from twenty-three pharmaceutical manufacturers. The compliance officers and other professionals attending the meeting all represented companies currently operating under Corporate Integrity Agreements…