Another critical element of the program are the yearly physician audits. But we want to provide enough information so they can make good decisions and then follow through with education and training. Merlo said a key outcome of a compliance program should be a culture that promotes doing the right thing and supports those individuals who promote this. This is especially important considering that fraud does not have to be an intentional act committed by a physician or researcher. Government regulators don't consider anything to be a simple mistake.
People think of the flagrant causes of fraud.
But the government looks at these other things, honest mistakes, as fraud. We recently had 290 physicians, residents, medical students and staff attend our formal education programs in one month. Nine people are part Merlo's office, which reports directly to the general counsel's office. Lynn Monahan serves as the University's compliance coordinator. It's a full-time job not only to educate ourselves but all the physicians, the administrators and staff.