New DOJ Compliance Initiatives Create Governance Challenges for Health Industry Companies

• March 10, 2023

• Michael W. Peregrine , McDermott Will & Emery LLP

Health industry boards are encouraged to evaluate and respond to a series of important new corporate compliance initiatives recently announced by the Department of Justice (DOJ). These initiatives, and corresponding changes to DOJ’s Evaluation of Corporate Compliance Programs (ECCP) guidelines, are an important leadership reminder that the presence (or absence) of a functioning compliance program is an important element of DOJ’s decision making in corporate fraud matters.