Looking back in time, the compliance field owes a lot to the healthcare industry.  In the 1990s, there was a dramatic explosion in the industry in response to aggressive federal enforcement programs and increasing regulation.  All of a sudden, compliance officers who sat in the backrooms of legal departments were “volunteered” to address proactive compliance.  Federal regulators pushed the compliance function to assume a much larger role at healthcare companies and to come out from under the shadow of legal departments and play a frontline role in mitigating risks.

As the regulatory frameworks became more complex, and as abuses were called out, a robust regulatory enforcement regime through the HHS Office of Inspector General grew.  The force behind the HHS-OIG multiplied with more regulations, additional enforcement needs and development of tools such as Corporate Integrity Agreements.

Given all of these trends and with a public spotlight on the industry, healthcare companies quickly realized that they had only one option – design and implement robust proactive ethics and compliance programs. 

In this Episode, Michael Volkov reviews healthcare compliance programs and the unique set of fraud risks.