Bolstering Our Best-in-Class Compliance Program

The PAN Foundation’s commitment to compliance allows us to continue connecting thousands of people with the healthcare they need, while demonstrating program integrity and effectiveness in a variety of ways, including:

• Providing assurance to enforcement and regulatory agencies that we are committed to preventing improper and unethical behavior and have sufficient safeguards in place.
• Demonstrating to our donors, partners and the public that our culture is one of integrity, ethics and good corporate citizenship.
• Providing necessary information to our Board of Directors so that they can exercise their oversight responsibilities.

Compliance Overview

Over the past year, PAN has enhanced its compliance program. Our ongoing compliance initiatives are intended to support an ethical culture, promote effectiveness and ensure that we meet all legal requirements and specifications set forth in PAN’s original Advisory Opinion and subsequent modifications, issued by the Office of Inspector General in the U.S. Department of Health and Human Services.

PAN’s compliance program incorporates all seven elements identified by the government as necessary for a comprehensive and effective program. As directed and overseen by the Audit, Risk Oversight and Compliance Committee of PAN’s Board of Directors, these elements include:

• Compliance program organizational structure and oversight
• Written compliance guidance
• Compliance education and training
• Lines of communication*
• Disciplinary and enforcement standards
• Auditing and monitoring
• Investigation of complaints, response to detected offenses and corrective actions

*Includes PAN's compliance hotline (1-866-580-6442), where complaints can be made, and issues raised on a confidential and anonymous basis.

Read more about these program elements in our Compliance Program Summary.

Compliance Leadership and Communications

In September 2018, PAN’s President and CEO Dan Klein and Chief Compliance Officer Tom Herrmann led a discussion on best compliance practices for independent charity patient assistance programs. The session was part of CBI’s Patient Assistance Program Legal Update Conference.

Speaking to pharmaceutical company representatives, pharmacy benefit managers, patient assistance advocates and legal experts, Mr. Klein and Mr. Herrmann discussed how independent patient assistance programs can develop and implement an effective compliance structure.

“PAN is committed to helping as many patients as possible get access to the care they need, while at the same time providing a safe harbor for our donors in adherence to all legal and regulatory guidelines," President and CEO Dan Klein said to participants.

PAN's compliance efforts were also nationally recognized in an article written by Mr. Herrmann and published in Compliance Today in November 2018 titled, “Effective Compliance for an Independent Charity Patient Assistance Program.” An excerpt:

"A compliance program needs to be responsive to the mission, structure and culture of an organization while also addressing the seven core elements referenced by the Federal Government. In addition, it should address the identified risk areas and be responsive to the needs of all stakeholders (e.g., government, donors, patients, physicians, pharmacists, contractors). …there is 'no one size that fits all organizations.' However, a compliance program should address the seven core elements and 'foster a culture of compliance that begins at the executive level and permeates throughout the organization.'"

Culture of Compliance

PAN’s comprehensive program is intended to ensure compliance with all applicable laws, regulations and government guidelines, as well as adherence to the specifications set forth in the OIG Advisory Opinion 07-18 (as modified). Relevant to all stakeholders—donors, patients, providers, pharmacies, Board members, employees and contractors—it's designed to foster a culture of compliance that begins at the executive level and permeates throughout the organization.