Strategic, Practical and Efficient
Creating and maintaining effective compliance and ethics programs can be a daunting challenge for any company—identifying issues, correcting problems before they become worse, and most importantly, preventing problems in the first place. A compliance failure can have enormous consequences for a company’s internal and external shareholders, including potentially ruinous fines and penalties, loss of revenues, government-imposed sanctions and integrity agreements.
We understand what’s at stake and know how to help companies build effective programs to cultivate and sustain a compliant and ethical culture. We understand not only the government’s regulatory and enforcement perspective, but we also have the business background to appreciate limited corporate resources and practical realities. As a small and nimble law firm, we can provide effective and efficient counsel and compliance services with the benefit of attorney-client privilege.
Building your positive compliance narrative
We identify, assess and prioritize your compliance concerns through a mix of risk assessment, targeted audits, focused remediation and corrective actions. Through thoughtful planning and documentation, we work with our clients to develop a positive, compliance-based company narrative that government prosecutors and regulators look for in determining whether to investigate or pursue an enforcement action.
Our experience includes work in the public and private sectors. The head of our practice group was the chief compliance and ethics officer for two pharmaceutical companies and was a federal prosecutor in the U.S. Attorney’s Office in New Jersey for a dozen years.
We develop and strengthen:
- Codes of conduct, compliance plans, policies and standard operating practices.
- Board of directors, executive and employee training programs on anti-kickback statutes, HIPAA compliance, the Stark Act, federal and state False Claims Acts, off-label marketing, government price reporting, FCPA and anti-bribery compliance.
- Risk assessment and annual audit programs.
- Compliance programs in high risk areas, including: incentive compensation plans; Medicare/Medicaid reimbursement; company hotline and communication; gifts and conflicts of interest; speaker, advisory board and consultant programs; educational, research and charitable grant programs; internal investigation protocols and procedures; and employment practices.