Please feel free to contact me anytime to share your thoughts: +1 612.357.1544 (cell), +1 952.567.6215 (direct), gerry.zack@corporatecompliance.org.
Early in the pandemic, when employees not directly involved in patient care were sent home, much was said about the importance of making modifications to internal controls in connection with compliance issues. Compliance professionals were wise to perform a rapid risk assessment to check on compliance vulnerabilities resulting from this sudden shift to remote work. Internal controls designed for an office work environment often need to be adjusted when employees are working from home. Failing to do so can create new compliance risks. I refer to this necessary shift as internal controls 2.0.