Understanding and Complying with Compliance Agreements

Abstract

Abstract A substantial number of compliance agreements, including Deferred Prosecution Agreements (DPAs), Non prosecution Agreements (NPAs), consent decrees, and administrative agreements such as Corporate Integrity Agreements (CIAs) with the Office of Inspector General within the U.S. Department of Health and Human Services (HHS), have forward-looking compliance-related provisions and obligations. These provisions generally mandate enhanced compliance systems and processes, seek to make compliance an integral part of the company operations, and attempt to drive positive culture changes