Daniel Gospin, a Member of the Firm in the Health Care and Life Sciences practice, in the Houston office, and Lesley Yeung, an Associate in the Health Care and Life Sciences practice, in the Washington, DC, office, cowrote an article titled "Compliance Program Effectiveness: Do You Really Need Outside Counsel, and How Does That Relationship Work?"
Following is an excerpt:
As compliance officers are well aware, one of the key factors corporate compliance program that must be "effective." Accordingly, an organization's corporate compliance program should evolving program that is evaluated from time to time, resulting in modifications and potential "retooling" to ensure its continued "effectiveness."
There can be a variety of reasons for why it has come time to do a compliance program effectiveness review. Maybe the organization has internal or external reporting obligations that require an evaluation of the compliance program to be conducted, maybe the organization has experienced a compliance breach, maybe the organization is about to go through an acquisition or due diligence process, or maybe it has just been a while. Whatever the reason, it is important for the organization to determine whether to engage outside counsel to assist with the review process. And if outside counsel is engaged, it is important to understand how that relationship generally works to ensure that a productive and meaningful evaluation is conducted.
The attached file is reprinted from Journal of Health Care Compliance, Volume 16, Number 3, May-June 2014, pages 21—26, with permission from CCH and Aspen Publishers, Wolters Kluwer businesses. For permission to reprint, e-mail permissions@cch.com.
