Jay Rosen discusses the combination of compliance and ethics programs with independent monitoring, as well as two DOJ memos that have been key in the selection and application of independent monitors.
The marriage of independent monitors and compliance and ethics (C&E) programs has been facilitated through the evolution away from strict regulatory compliance to a more ethics-based compliance. This has been one of the most significant advancements in independent monitors over the history of AMI. Early on, the company had independent monitorships in the health care industry around such issues as billing and coding. From there, as the focus of regulators expanded, AMI began to address other issues, such as codes of conduct and conflicts of interest.
Thus, we were well-suited to move into a more direct, ethics-based compliance independent monitorship as the first decade progressed.
In the late part of the past decade, AMI began to move into more Department of Defense (DOD) independent monitorships around suspension and debarment. Suspension and debarment officials (SDOs) in the DOD were very much focused on the ethics side of compliance in the oversight of companies going through the suspension and debarment process. Administratively, these SDOs would use the suspension and debarment rules to have companies…
