Risk Assessments
One clause of the OIG's guidance requires "the use of audits and/or other risk evaluation techniques to monitor compliance, identify risk areas, and assist in the reduction of identified problems." This mandate has caused pharmaceutical firms to scramble, using scattershot auditing approaches to respond to the government's guidance. Unfortunately, this "boil the ocean" tactic is not the most effective approach. By addressing all potential risk areas in a uniform manner, companies risk overlooking the most pressing issues, addressing minor infractions rather than major abuses. To remedy this, a structured risk assessment framework is recommended so that your company can identify those areas that should be addressed immediately versus those that should be subsequently addressed. Polaris has a methodology that will allow you to do this.
