How Will the DOJ’s New Compliance Expert Evaluate Your Program? [Infographic]

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broadcat iconCourtesy of The Broadcat
Ricardo Pellafone (ricardo@thebroadcat.com)

Since you’re the type of person that’s reading a compliance blog, let’s go over a few things that you probably already know, but your business clients don’t.

  1. You know that the Department of Justice has hired their own compliance expert to help them evaluate the compliance programs of companies that run into trouble.
  2. You know that this expert is Hui Chen, formerly of Standard Chartered Bank, Pfizer, and the DOJ.
  3. You’ve already read the speech Leslie Caldwell delivered on November 2, where she outlined the metrics Ms. Chen will use when evaluating compliance programs. And you thought “well, that sounds pretty similar to the the Filip memo.”

But the businesspeople you support don’t know any of that, because that’s not their job. And they don’t have time for the full backstory.

So here’s a simplified, visualized summary that you can use.

How the DOJ's New Compliance Expert Will Evaluate Your Program

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92 COMMENTS

    • Hi Michelle – If you wouldn’t mind sending me your email, I can send it to Ricardo. Or you can email him directly for your free PPT (ricardo@thebroadcat.com).

      Thanks!

    • Consider it an early birthday gift…something for all compliance professionals to look forward to…
      Please share the Power Point presentation you referenced. What a great way to “simplify” compliance.

  1. Could you please send a PowerPoint copies of all the compliance infographics you have available. Thanks you and great work!

    • Hi Russ, I didn’t get your email through the comment. If you wouldn’t mind sending it to me, I can send it to Ricardo. Or, you can feel free to email Ricardo directly (ricardo@thebroadcat.com) and he will be happy to send you the information.

      Thanks!

  2. This is awesome and a whole lot easier to facilitate “buy in” from the business. I would love to receive the PowerPoint version. Thanks!

  3. I really like that the infographic focuses on translated and localized policies. A key factor often overlooked. Thanks for sending me copy of the Power Point.

  4. The presentation displays the information beautifully. I would appreciate a copy of the PowerPoint presentation to use within our company. Thank you!

  5. Love the graphic – what a clever way to present the information! I’d appreciate the PPT as well, thanks!

    • Hi Jim,
      We didn’t get your email address. You can either send it to me and I can forward it to Ricardo, or you can email him directly and he’d be happy to send you the PPT (ricardo@thebroadcat.com)

  6. Thanks for the awesome infographic. I was at the Seton Hall Healthcare Compliance Certification Program/Conference a couple weeks ago, and the hiring of Ms. Chen was discussed. I am very interested in how the DOJ’s hiring of a seasoned compliance professional impacts their outlook and enforcement. I would love the ppt presentation as well. It can be sent to rhathaway@acog.org. Thank you!

    • This is so clear and direct in the information and a powerful message.
      Please email me a copy of the slides. I present in 2 weeks to my management team.

  7. I attended a DOJ debriefing this morning in Manhattan and there was quite a bit of discussion about Ms. Hui Chen’s role and how having her expertise will actually be beneficial to both parties. Prosecutors and defense attorneys both agree that she is ethical and fair and very experienced when t comes to compliance programs and effective implementation. The panel concurred that she brings a very impressive background and that she is the perfect fit for the role. One member did say that they hope she will be open to the fact that compliance programs come in all shapes and sizes as she is use to working with organizations with very robust resources and gold seal programs.

    I can share that one take away message today from the DOJ is that they want to know what was done when an incident occurred. Another topic discussed today was how compliance officers are being held personally liable when compliance fails.
    The panel discussed and shared opinions on the Yates Memo which prioritizes the manner in which Government civil and criminal law enforcement investigations are conducted. It begins by proclaiming that “One of the most effective ways to combat corporate misconduct is by seeking accountability from the individuals who perpetrated the wrongdoing . . . [accountability] it deters future illegal activity, it incentivizes changes in corporate behavior . . . and it promotes the public’s confidence in our justice system.”

    They discussed the importance of educating staff of their rights during and investigation and the requirement to cooperate. The panel brought up the Upjohn warning and how employees should be aware that they have the right to counsel and that the organization’s counsel is not their counsel…

    Great debriefing on compliance expectations from both the DOJ, corporate organizations, and legal defense perspective. The discussion was not specific to healthcare but relevant just the same. I tried to slip a question in asking how Ms Chens position will impact enforcement of the OIG compliance program requirement as a condition of enrollment in Medicare under the ACA.

    Did anyone else notice that this is also mentioned in the OIG 2016 work plan?

Comments are closed.