CASE STUDY

Compliance Program Effectiveness Reviews

Saranac has assessed the efficacy of ethics and compliance programs in a number of settings, including pre-acquisition due diligence for financial sponsors and independent reviews for boards of directors focused on fulfilling their oversight responsibilities. We evaluate the cultural foundation of the program, its design and operation, and the efficacy and span of its controls and reporting channels. The review typically culminates in a report that incisively identifies critical gaps as well as key areas for continuous improvement. In some instances, Saranac clients have submitted these reports to regulators, including the Centers for Medicare and Medicaid Services and the Office of Inspector General.

This work can be highly impactful. When a global medical device company operating under federal Deferred Prosecution and Corporate Integrity Agreements disclosed to the corporate monitor, as well as regulators and enforcement agencies, problematic conduct, the Nominating, Compliance and Governance Committee of the Board of Directors retained Saranac to assess the effectiveness of the compliance and ethics program. The expedited review culminated in a set of recommendations that were discussed with the monitor and government officials and quickly implemented. The term of the Deferred Prosecution Agreement and monitorship was extended for an additional year but no other enforcement actions were initiated.