Better Health Care Industry Practices for Effective Corporate Compliance Programs, in Corporate Compliance Insights

George Breen, a Member of the Firm in the Health Care and Life Sciences practice, in the Washington, DC, office, and Sarah diFrancesca (Giesting), an Associate in the Health Care and Life Sciences practice, in the New York office, cowrote an article titled "Better Health Care Industry Practices for Effective Corporate Compliance Programs."

Following is an excerpt:

Health care providers, suppliers and manufacturers continue to face significant government enforcement activity as a result of increased government funding and greater coordination among government agencies for fighting fraud, waste and abuse. The Department of Justice recently announced that it recovered $5.6 billion in civil and criminal fraud investigations in fiscal year 2011 and that nearly $6.5 billion has been recovered since January 2009 from fraud involving the federal health care programs.

There is a renewed demand by government enforcers that health care companies implement compliance programs. Government enforcers also have taken steps to increase enforcement activity against individuals who participate in the misconduct of the company.

Health care companies must respond to this growing governmental pressure with the development, implementation and execution of an effective corporate compliance program. This article provides an overview of some better industry practices designed to enhance the effectiveness of a corporate compliance program.