Every compliance officer knows that regulatory oversight and enforcement will continue unabated in 2012. However, here are five factors that could make the risk management challenge even greater in the New Year:
• External Forces
o Responsible Corporate Officer Liability
o Increased collaboration between FDA and OIG
• Internal Forces
o Regulatory knowledge gaps
o Disconnect between marketing and medical/regulatory/legal/compliance functions
o Untrained promotional agency vendors
By actively addressing internal forces within their control, drug and device companies can create a less vulnerable organization in the face of external regulatory compliance pressures.
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