Fighting fraud continues to be a major healthcare priority. Although many of the recent cases have involved big pharma, medical device companies are on the government's radar. Device makers need to be acutely aware of what’s happening within their organizations, because most fraud cases are initiated by whistleblowers. According to Michael Sullivan, partner at Ashcroft Sullivan LLC (Boston), a recent study found that 70% of employees are more likely to report a problem to the government first than to their own company. For this reason, Sullivan, a former U.S. Attorney for the district of Massachusetts, advised attendees at MDMA’s annual meeting in Washington, DC last week that it’s critically important to know their industry as well as their company’s risk profile—it’s people, culture, and systems. One of the best ways to prevent fraud within a company is to establish an effective compliance program that stresses using systems and technology to control and monitor activities, advised Michael Bell, president of R-Squared (Princeton, NJ). “A strong program can be the difference for whether a prosecutor pursues a case,” said Bell. He emphasized the importance of doing things right the first time around and making sure that your compliance program is up to par. Some of Bell’s tips for best compliance practices: • Have more of the company's board and senior management involved. • Place more emphasis on process standards and benchmarking. • Embed compliance into business workflow (as opposed to using a stand-alone compliance program). • View compliance as a continuous business improvement process that has a true return on investment. • Prioritize financial relationships with referral sources (consulting relationships, educational and research grants, emerging state laws, and aggregate spend).