The Role of Internal Audit in Health Care Compliance

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Presentation transcript:

The Role of Internal Audit in Health Care Compliance Pharma Congress June 2003

Audit/Compliance Interaction

Annual Audit Plan Areas at risk identified Educational grants Speakers’ programs Samples Medicaid and contract rebates Clinical grants Other promotional activities Greater risk weighting assigned Areas audited more frequently

What Do We Look For? Awareness of the laws by appropriate employees Procedures in place to ensure compliance with laws Test of transactions to help ensure laws are actually being complied with Work closely with Legal to resolve “grey” areas identified through audits

Role of Internal Audit Work with Legal and Pharmaceuticals Division to ensure procedures put in place are appropriate and auditable Train audit staff on the appropriate laws Investigate potential violations of laws

Audit Workprograms Educational Grants Speakers Programs Compliance approach to workprograms: Educational Grants Speakers Programs

Educational Grants Ensure avoidance with anti-kickback statutes Nature and purpose of the grant Monies spent in the proper manner Monies left on the table

Speakers Programs Review the content of programs selected for audit Review of attendees and costs – should be modest Review of accompanying activities