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1 What's in a Name?

You may have noticed that some organizations have compliance programs, and others have ethics/integrity programs. They are often considered synonymous, but a subtle distinction can be made between the two terms. It is generally thought that the title “compliance program” implies a primary concern with following rules and regulations, whereas the title “integrity program” puts the emphasis on values and doing the right thing. There may be differences in approach and subtleties of content, but there are basic elements common to both compliance and integrity/ethics programs. Those common elements, whatever the title of the program, are the focus of this book, although for convenience sake the term “compliance program” will be used throughout. Each organization must choose a title—or perhaps create an entirely new title—depending on its needs and culture.

You may not be aware of it, but there are probably many compliance activities already occurring in your organization. Things like employment and labor laws, the Equal Employment Opportunity Commission (EEOC) and Employee Retirement Income Security Act (ERISA) regulations, Department of Labor wage and hour rules, Occupational Safety and Health Administration (OSHA), Nuclear Regulatory Commission requirements, Joint Commission survey preparation, American Association for Accreditation of Ambulatory Surgery Facilities, Inc. (AAAASF)—these are all compliance-related activities. Increasingly, too, other areas have come under close compliance scrutiny, such as academic research. Departments coordinating such research activities in your organization should have a compliance-related process dedicated to risks associated with research. This could be a stand-alone compliance program or could be a part of the corporate compliance program.

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