As reflected in recent remarks by Deputy Attorney General Rod Rosenstein, the United States Department of Justice (DOJ) is “reinforcing its relationship with good corporate citizens” by coordinating with, and considering, the fines and penalties other authorities are seeking in enforcement actions against corporations. This increased coordination among enforcement bodies also is meant to “help to identify culpable individuals and hold them accountable.”

This white paper will explore recent governmental enforcement activity including the evolution of settlement agreements (Corporate Integrity Agreements [CIA] and Deferred Prosecution Agreements [DPA]), which provide a perspective on the Department of Health & Human Services (HHS) Office of Inspector General’s (OIG) and DOJ’s priorities for healthcare compliance program structure and content. The resulting impacts from a mandated CIA or DPA can be mitigated if entities have a clear understanding of the government’s current enforcement efforts and use that knowledge to implement and maintain effective compliance programs.