By Adam Turteltaub What makes for an effective compliance program, not just from a legal perspective but from a practical one? Getting that answer, and sharing it is the focus of the LRN 2024 Ethics & Compliance Program Effectiveness Report To learn what it contains we sat down with Meredith Hunt (LinkedIn), Ethics and Compliance Specialist at LRN. In this podcast she shared that more effective programs are focused on values rather than rules, and underscore the importance of ethical culture. They are also taking a risk-based approach. Their research also revealed the importance of adaptin ..read more

By Adam Turteltaub The 340B Drug Pricing Program was created to protect safety net hospitals from rising drug prices. It allows them to purchase outpatient drugs, and pharma companies to sell those drugs, at a discount. In this podcast, Jason Reddish (LinkedIn), Principal and Mark Ogunsusi (LinkedIn), Associate, at Powers Pyles Sutter & Verville provide an overview of the program and the compliance requirements. They are also two of the authors of the chapter “Pharmacy:  340B Drug Pricing Program” in the Complete Healthcare Compliance Manual. The 340B program helps hospitals that are ..read more

By Adam Turteltaub In January 2024 the US Attorney’s Office for the Southern District of New York (SDNY) set a shockwave through the business world by announcing a new whistleblower pilot program. To understand what the policy says and what it likely means for compliance programs, we spoke with Todd Haugh (LinkedIn), Associate Professor of Business Law and Ethics, Arthur M. Weimer Faculty Fellow in Business Law at the Kelley School of Business at Indiana University. Under the policy, he explains, individuals who have participated in a fraud may be eligible for a non-prosecution agreement, if t ..read more

By Adam Turteltaub In late 2023, The Office of Inspector General (OIG) at the Department of Health and Human Services issued its new General Compliance Program Guidance. In this podcast, David Schumacher, Partner and Co-Chair of the Fraud & Abuse Practice at Hooper Lundy & Bookman explains that this document is both evolutionary and revolutionary. For years the OIG’s office had been offering guidance through the Federal Register. To make that information more accessible it moved it online, consolidated the information, added interactive features and created a much richer resource which ..read more

By Adam Turteltaub Tired of being last to the party and then perceived as a party pooper? There’s a solution to that problem embraced by Dana McMahon, Global Chief Compliance Officer, Head, Privacy & Enterprise Risk at Stryker. She works to have her team embedded in the business unit. It’s a process that begins with getting a seat at the table and being intentional about conversations. From there the relationship evolves into being a consultant on sticky issues and then on to being integrated into decision making and proving yourselves indispensable. The key to the process, she explains, i ..read more

By Adam Turteltaub At the center of managing cyber risk in healthcare sits the Health Sector Coordinating Council Cybersecurity Working Group (LinkedIn). In this podcast, Executive Director Greg Garcia explains that healthcare has been designated as a part of the critical infrastructure, and the council has as its mission to: “identify systemic cybersecurity threats to critical healthcare infrastructure; collaborate on guidance and policies for mitigating those risks; and promote threat preparedness and incident response awareness and activities.” It’s a needed mission. The number of data brea ..read more

By Adam Turteltaub The FCPA sure isn’t what it used to be, or is it? While the headline grabbing Foreign Corrupt Practices Act cases are much less frequent than they once were, there is still substantial risk both for individuals and companies, as recent dispositions have shown. To understand where things are we sat down with Markus Funk, partner at Perkins Coie and author of the chapter “Anti-Bribery and Corruption Compliance Programs” in The Complete Compliance and Ethics Manual 2024. He explains that just because there aren’t cases in the news, doesn’t mean all is quiet. There may remain a ..read more

By Adam Turteltaub Krista Muszak is organized. More importantly, the longtime compliance professional and Senior Manager, Regional Process & Optimization Lead for Pfizer knows how to keep others organized as well. She will be sharing some of this wisdom in Nashville at the 2024 HCCA Compliance Institute in the session “Muda, Mura, Muri to Veni Vidi Vici: Applying Project Management and Process Improvement to Your Compliance Program.”  She also shares a bit of it here in the latest Compliance Perspectives podcast. First, she explains that the title comes from terms used by Toyota to im ..read more

By Adam Turteltaub When it comes to compliance technology, there are two challenges. First is finding the right solutions to increase your programs effectiveness. Second is securing the resources to acquire and deploy the technology. Parth Chanda, Founder and CEO of Lextegrity, covers both topics in this podcast. When it comes to tech, he explains, you want tools that give you the confidence that your program is effective in practice and not just on paper. You also need to prioritize based on risk, and your organization’s own experience with technology. If the history is short or non-existent ..read more

By Adam Turteltaub Imagine you are at a large company with thousands of suppliers. As a part of the compliance team you need to understand the risk of working with each and every one of them. To do that you may need to understand the ownership structure, where they source materials, where and how they manufacture, and a host of other data about each and every one of them. That’s a daunting task. It’s also one that Jenna Wells, Chief Customer and Product Officer at Supply Wisdom believes is ideally suited for AI. With human supervision it can help with such a large, seemingly impossible underta ..read more