Search Matters

Host Organization to propose 4 or 5 candidates and Reporting Agency selects. Cites specifically using DOJ Policy.

Independent third party, not an employee or agent of Host Organization and whose work is not subject to attorney client or work-product privilege. Will have: access to sufficient resources to meet duties under multiple DPAs (this matter combined an FCPA action against Olypus Corporation of Latin Amercia); experience with internal investigations or the investigative process; absence of a prior relationship with the Host Organization from 1/1/2001 to present; absence of current representations by Monitor or his/her firm adverse to Reporting Agency. To also be considered: prior Monitorship or oversight experience; experience with federal health care laws, regulations and programs; experience with the health care industry; experience with the FCPA.

Evaluate Host Organization's compliance with the Agreement, as well as another Agreement (DPA with Olympus Corporation of Latin America - FCPA).

Conduct a review and evaluation of all policies, practices, and procedures relating to compliance with the Agreements and the following subjects: effectiveness of procedures to track the use of field assets, including but not limited to demonstration products and products loaned to customers; procedures and practices used to select, engage, and pay consultants; procedures and practices for considering and awarding grants; effectiveness of the procedures and practices to ensure that any payments comply with the law; effectiveness of the training and education programs regarding federal health care laws concerning relationships between Host Organization and customers, including the Anti-Kickback Statute, the FCPA, ethics and compliance, and corporate governance issues relating to federal health laws. Please see Agreements for full listing.

No prior business relationship from 1/1/2001 to present. No business with Host Organization for a period of one year after the expiration of the Monitorship.