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Healthcare compliance investigations during a global pandemic

Alyssa S. Lawrence (alyssa.lawrence@miami.edu) is Senior Director, Compliance, and Hannah G. Kent (hannah.kent@miami.edu) is Compliance Specialist at University of Miami Health System in Miami, FL.

Effective compliance programs serve to prevent and detect criminal conduct and promote a culture of ethics and compliance with the law. Conducting investigations on allegations of misconduct is integral to this process. The current worldwide pandemic has altered the normal investigations process by requiring creative solutions to unforeseen roadblocks. Nevertheless, compliance officers can still conduct thorough investigations by being flexible and remaining committed to high standards.

The requirements for an effective compliance and ethics program are outlined in the Federal Sentencing Guidelines.[1] The Federal Sentencing Guidelines are recommendations set by the U.S. Sentencing Commission that outline voluntary guideposts for federal courts in criminal cases. The guidelines stipulate that an effective compliance and ethics program can reduce sentences for a company’s federal offenses. The historical diligence of a company’s compliance program has a “direct bearing” on the penalties and probation should the company be sentenced for a criminal offense. Specifically, the guidelines task prosecutors to assess the company’s process for handling investigations of noncompliance, including whether the company directs complaints to the appropriate personnel, completes investigations in a timely and thorough manner, and conducts the proper follow-up and discipline.[2] It therefore remains highly important to uphold the quality of compliance investigations throughout this prolonged period of new challenges.

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