Implementation History at UW
On April 22, 2005, President Mark Emmert sent an e-mail to the deans and cabinet members in which he said: "With the most recent example of compliance issues, we have again been reminded that we have not yet created the culture of compliance that we have discussed on many occasions." He went on to say that "the creation of a culture of compliance needs to be driven by our core values and commitment to doing things the right way, to being the best at all we do – We need to know that the manner in which we manage regulatory affairs is consistent with the best practices in existence."
The Sentinel Event: Largest Fine at a Medical School
The Collaborative Enterprise Risk Management Report for the University of Washington (2006) began with the following: "Over the past few years, the UW has been confronted by a series of problems with institution-wide implications, including research compliance, financial stewardship, privacy matters, and protection of vulnerable populations" (p. v). The situation with the highest impact on the university began when Mark Erickson, a UW compliance officer, filed a complaint alleging fraud in the UW's Medicare and Medicaid billing practices. The 1999 complaint prompted a criminal investigation, guilty pleas from two doctors, and a civil lawsuit resulting in the $35 million settlement, the largest settlement made by an academic medical center in the nation. The federal prosecutor claimed that "many people within the medical centers were aware of the billing problems" and that "despite this knowledge, the centers did not take adequate steps to correct them" (Chan 2004). UW's 2006 ERM Annual Report acknowledges that, in addition to the direct cost of the fines, there were also indirect costs in terms of additional resources for reviews of university procedures, increased rigor and frequency of audits, and an incalculable damage to the university's reputation. The federal prosecutor acknowledged that UW's efforts to reform its compliance program have been "outstanding" (Chan 2004). He further noted that since the lawsuit was filed, the university "has radically restructured their compliance office. The government is very pleased with the efforts the UW is taking to take care of these errors."