Episode 61 – Drug Pricing: New OIG Guidance Reaffirms the Seven Elements of an Effective Compliance Program

In November, the Department of Health and Human Services’ Office of the Inspector General (OIG) issued new compliance program guidance that affirms OIG’s long-standing focus on the seven elements of an effective compliance program, first published in 2003. In this episode of Connected With Latham, partner Chris Schott and associate Danny Machado are joined by guest Lynn Robson of United Therapeutics. They discuss how the OIG’s compliance framework is relevant to drug manufacturers, how past enforcement actions can inform implementation of a compliance program, and how an effective compliance program can be beneficial in the enforcement context.

 

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