In the Beginning

by | Dec 22, 2025 | Pastin Reports


THE PASTIN REPORT

BEST COMPLIANCE PRACTICES

December 8, 2025

Icons of Compliance Subjects

In the Beginning

Before I began working on healthcare compliance, I worked on compliance in the defense and financial services industries. One day we got a call from a healthcare company with a compliance problem. We knew that the new IG at HHS, June Gibbs Brown, was well known for cleaning up the defense industry through ethics and compliance programs. So we looked at over 6,000 healthcare entities to see what organizations were doing. We found zero ethics or compliance programs. None. Today’s healthcare organizations will tell you that they have ALWAYS been committed to ethics and compliance. Maybe. But that commitment was not expressed through a formal commitment to compliance until the feds forced the issue. Your jobs did not exist. And they may not exist in the future.

Quick Summary

Today healthcare organizations are dramatically cutting back operations and overhead in anticipation of significant cuts in Medicaid and Obamacare reimbursement. Compliance is viewed as overhead. Most large fraud settlement cases were not initiated by OIG or DOJ. They were initiated by whistle blowers using the stand-in-the-government’s shoes provision of the FCA. This provision is under a serious challenge working its way through the federal courts. The FCA also protects compliance professionals. The stance of the current IG is not yet clear. It appears that the all important future compliance guidance documents may not be forthcoming. These factors combine to threaten the future of the compliance profession. While organizations want us to believe that the commitment to compliance is part of their identity, history does not support that view. Some of the time, I am able to convince myself that compliance is well enough entrenched to weather this challenge. But compliance professionals and functions need to be ready to fight hard to maintain their current status.

Our Stance

When the Health Ethics Trust was established in 1995, there were no other healthcare compliance organizations. We partnered with the University of North Carolina at Chapel Hill to establish the Healthcare Best Compliance Practices Forum so that healthcare organizations could learn about compliance without hiring consultants, lawyers and so on. The 30th Annual Forum just occurred. We plan to be here even if the going for healthcare compliance gets tough. We have initiated a robust scholarship program to support compliance professionals whose budgets are shrinking. We believe that despite current cutbacks, healthcare compliance is here to stay. So are we. Join us February 18 – 20, 2026 to learn more.

Mark Pastin, Ph.D. is President of the Health Ethics Trust, a division of the Council of Ethical Organizations, established in 1993 to assist healthcare organizations in all aspects of compliance program operation and development.

Copyright, 2025, Health Ethics Trust/Council of Ethical Organizations

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