#ACIFCPA ACI’s FCPA & Anti-Corruption for the Life Sciences Industry Daniel Garen SVP & Chief Compliance Officer Wright Medical Technology, Inc. Detecting and Monitoring Corruption Across Your Operations: First-Hand Insights on How to Work with Compliance Monitors, and Leverage Your Internal Audit Function, Data Analytics and Metrics Brent White Vice President, Internal Audit Allergan Joshua Torok Associate Director, Internal Audit PPD, LLC April 28-29, 2014 Sara Vandermark Analytics Senior Manager Deloitte Financial Advisory Services LLP Tweeting about this conference?
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Detecting and Monitoring: Corruption Across your Operations
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#ACIFCPA
ACI’s FCPA & Anti-Corruption for the Life Sciences Industry
Daniel Garen
SVP & Chief Compliance Officer
Wright Medical Technology, Inc.
Detecting and Monitoring Corruption Across Your Operations: First-Hand Insights on How to Work with Compliance Monitors, and Leverage Your Internal Audit Function, Data Analytics and Metrics
Hotline Web 0 0 0 0 0 0 Violation of Policy 0 0 0 0 0 0
Letter/Mail 0 0 0 0 0 0 Other 0 0 0 0 0 0
Phone 0 0 0 0 0 0
Other 0 0 0 0 0 0
Area Involved 13Q1 13Q2 13Q3 13Q4
EOY
2013
EOY
2012
Sales 0 0 0 0 0 0
Management 0 0 0 0 0 0
Other 0 0 0 0 0 0
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Corrective and Preventative Action Committee
CAPA Input Sources
0
5
10
15
20
25
Investigations HCP SpendViolation Reports
CIA Items Other
Assigned Action Items
0
10
20
30
40
50
60
70
80
90
Late
Other
Total
Linear (Total)
0 0 0 0 0 0
0 0 0 0 0 0 0 0 0
#ACIFCPA
Administration • Compliance Budget Status:
• Budget
• Actual
• Difference
• Open Headcount: #
• XXXXX
• Transitions: # hires
• Hires: XXXXXX
• Six Month Consultant Needs: Decrease/Increase/Flat
• XXXXXX (decrease)
• XXXXXX (increase)
• XXXXXX (decrease)
• XXXXXX (flat)
• Proposed New Headcount: #
Q1 Q2 Q3 Q4 EOY
$0 $0 $0 $0 $0
$0 $0 $0 $0 $0
$0 $0 $0 $0 $0
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#ACIFCPA
Process Walk Throughs
Personnel Interviews
Compliance Culture
Policy Knowledge
Overall Adherence
Detail Testing
Ensures and risk areas are identified and routinely monitored as well as assuring that WMT has policies and procedures
that are in line with Regulatory Guidelines.
Review and Monitoring – Process Focus
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Customer Facing / Focus Arrangement
On-going DPA/CIA Processes
Compliance Policy
Compliance Project Activities:
• Sales Force Audits
• Healthcare Provider Spend
• Consultant Contracts
• Healthcare Provider Payments
• Medical Education
• Grants and Charitable Donations
• Tone at the Top
• Ride Alongs
• Compliance Investigations Process
• Transparency & Aggregate Spend
• Sales Force Communication
• Anti Bribery Anti Corruption – FCPA
Review and Monitoring – Project Areas
#ACIFCPA
ACI’s FCPA & Anti-Corruption for the Life Sciences Industry
Daniel Garen
SVP & Chief Compliance Officer
Wright Medical Technology, Inc.
Detecting and Monitoring Corruption Across Your Operations: First-Hand Insights on How to Work with Compliance Monitors, and Leverage Your Internal Audit Function, Data Analytics and Metrics
Brent White
Vice President, Internal Audit
Allergan
Joshua Torok
Associate Director, Internal Audit
PPD, LLC
April 28-29, 2014
Sara Vandermark
Analytics Senior Manager
Deloitte Financial Advisory Services LLP
Tweeting about this conference?
#ACIFCPA
Anomaly detection based on predefined indicators can help isolate risky transactions and entities
High-level view Detailed view
Drill-down to a particular region
For illustrative purposes only
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Predictive analytics can help identify trends and improper payments
For illustrative purposes only
In t
ho
usa
nd
s
Vendor payment activity
What-if scenario
Trend Analysis
For illustrative purposes only
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Using text analytics to identify anomalous expenses Analyzing large text data sets and grouping it in clusters of strings by similarity can help identify abnormal text strings
In this example, upon quick review of the clusters (each color is one cluster with similar text), a cluster containing “exotic massage” was identified, and set apart for further investigation.