Rethinking the Pharma Compliance Profession

Patrik Florencio & Donna Boehme – Policy & Medicine – July 2019

They say, ‘the best predictor of the future is the past.’ But if you’re a pharmaceutical compliance officer, you’re hoping that saying isn’t true. We’re not talking about the more than $25 billion in fines that pharma and biotech companies have paid since the early 2000s. We’re talking about the reactive and nonstrategic evolution of our compliance profession to date. As compliance professionals, we’re so over- whelmed by our day-to-day grind that there’s no time to take a step back to remember how our profession was born, and how it has evolved until now.

Most importantly, there’s no time to consider what steps we need to take now to grow the impact and significance of our profession in the next phase of its evolution. But if we don’t grab hold of the reins, our profession will continue to be defined and shaped by what happens to us (reactive), instead of by what we make happen (proactive). We may never reach the full potential of our profession as the consolidator and overall manager of corporate risk. We may never become the profession we could be: the one which provides the CEO and the Board with a 360-degree view of risks across all functions, along with the high- level and comparative strategies, resources, and plans needed to manage those risks.

In this article, we begin by examining the evolution of our profession to date to see what lessons we might learn, so our future is neither predicted nor limited, by our past. We then present a proposed roadmap for transforming our narrowly defined compliance-based profession into a broad risk-based profession with greater potential. While our ideas may not be immediately practicable at some companies due to political or other considerations, we hope the road- map will resonate with every compliance professional and be adopted by many companies. Regardless of the outcome, we hope that this article begins an ongoing and proactive conversation about our future.

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