Creating a Robust Pricing Compliance/Audit Program That Will Provide the Most Accurate Calculations and the Ability to Verify Them

Foley Partner Lena Robins is speaking at the American Conference Institute’s (ACI) 7th Annual Advanced forum on Government Regulation of Prescription Drug Pricing, March 11 – 12, 2009 in New York, New York.

Ms. Robins is speaking on March 11, 2009 at 4:15 p.m. Her session is titled “Creating a Robust Pricing Compliance/Audit Program That Will Provide the Most Accurate Calculations and the Ability to Verify Them.” Topics to be covered include:

• Developing a compliance program that conforms to HHS OIG draft Compliance Program Guidance for the pharmaceutical industry
  
• Reducing risk in the three areas identified by the OIG as the most problematic:
  
  
  
  • integrity of data
    
  • kickbacks and illegal remuneration
    
  • samples
  
  
• Defining the relationship between the government pricing function and the compliance department
  
  
  
  • what role does or should the finance department play?
  
  
• Weighing the pros and cons of outsourcing calculations
  
  
  
  • what can or should be outsourced?
  
  
  • ensuring that outsources calculations are correct
  
  
  • what is the government’s position on outsourcing calculations?