Saving Independence -“Compliance” vs “Integrity” Officer

It happens every few years.  The top compliance job gets a new title.  Just in the past 25 years in life sciences, I have seen four major changes.  First, there was Compliance Coordinator (my original title).  Then that was changed to Compliance Officer.  Later the “Chief” was added.  A few years ago, we became Compliance and Risk Officers  Now as Maurice Gilbert’s recent article indicates, the latest version is “Integrity…

Transparency’s Uncertain Future

I just returned from speaking at CBI’s 10th Annual Forum on Transparency and Aggregate Spend.  After 10 years and 3 CMS Open Payments reporting cycles, I’m struck by how uncertain the once bright future of the Sunshine Act is.  Overall, the industry remains mired in a transactional mud under increasingly gray skies. Too many companies still obsess about putting the right transaction (or transfer of value or (ToV)) into the right…

CVS, Opioids & Lack of Compliance

The Year of the Pharmacy continues as CVS again makes negative headlines involving opioids.  This time, a pharmacist in Georgia is accused of stealing more than 3,000 pills from them including oxycodone, morphine, Dilaudid, and Adderall.[1]   Inflaming matters, the pharmacist allegedly stole the narcotics by ingesting them in the store – on camera.    The theft was discovered only when a new pharmacist found empty bottles.  Bottles that the store’s…

The Government Doesn’t Have to Win to Inflict Pain

Since the recent publication of the so-called Yates memorandum [1] setting out the Department of Justice’s (DOJ) strategy of targeting individuals for prosecution, we’ve seen several recent cases where the Government has not secured a conviction.[2]  For some companies, this has strengthened their resolve to resist instituting a compliance program. However, I can relate from personal experience working at a company under Government indictment that the DOJ doesn’t need to…

Pharmacy Woes Continue – Pharmacists Facing Jail Time

Earlier this year, we predicted that 2016 was going to be the Year of the Pharmacy, and not in a good way.  It seems we were right as the pharmacy woes continue.  This week  two Alabama pharmacists agreed to plead guilty in connection with the deaths of nine (9) patients.  The cases date back to 2011 and involve the compounding pharmacy Advanced Specialty Pharmacy doing business as MedIV.  The pharmacy…