The December 1-4 course is called "The Eighth Guideline: Operationalizing Your Corporate Health Compliance Program." The title is a reference to the federal government's seven-point system for implementing a successful compliance program, which includes guidelines such as keeping lines of communication open and monitoring compliance on an ongoing basis. Many of the executive education courses in the compliance area don't get beyond the basics and are only introductory, "compliance 101" courses, comments Michael Myers Jr., one of the faculty for the Eighth Guideline course and director of health compliance strategies for the Northeast Region Health Care Regulatory Group of the giant accounting and consulting firm of PricewaterhouseCoopers L.L.P. Myers says the Eighth Guideline course stands out because it is more advanced and geared to the compliance officers and senior-level managers who are ready for a nuanced, sophisticated approach to the topic: "We are going to be dealing with issues like how does compliance affect an organization, conflict resolution, and what to do to respond to external organizations."

Elizabeth Martin, director of programming for the Center, notes that the course will take on some of the practical, nitty-gritty aspects of compliance, including a "drill down" on useful skills and strategies. The theme of the course's first day is what organizational commitment and cultural adaptations result from compliance programs. Day two is devoted to how compliance officers should respond to an array of organizational and legal issues and pressures. Day three is set aside for practical applications and discussion of a Harvard Business School-style case study.

Besides Myers, the course's faculty includes Andrew Ward, partner-in-charge of PricewaterhouseCoopers's Health Care Regulatory Group, and other PricewaterhouseCoopers consultants. Representing the legal world are members of the prominent New York City-based law firm, Epstein, Becker & Green, including Steven Epstein, founding member of the firm, and

Stuart Gerson, chair of the firm's national litigation practice and acting United States attorney general in 1993 during the Bush administration. The Harvard University faculty contingent includes Arthur Miller, Bruce Bromley Professor of Law at Harvard Law School, and Troyen Brennan, professor of law and public health at the School and professor of medicine at Harvard Medical School. Miller is slated to open the course with a stage-setting talk, "The Evolving Legal Framework for Corporate Compliance Programs." David A. Shore, Pricewaterhouse-Coopers Director of Continuing Professional Education at the School and assistant dean, comments, "The strength of this program is that we are bringing all these organizations and their expertise together."

Compliance programs are supposed to be self-policing efforts designed to preempt the need for government action to force a company to stick to federal rules, explains Myers. In fact, the legislative roots of today's compliance programs are embedded in federal legislation passed in 1984 that was aimed at curbing fraud and abuse of federal programs. Compliance is now very much on the radar screen of health care executives for several reasons. Starting in 1997 with commercial laboratories, the Office of the Inspector General of the Department of Health and Human Services has rolled out a series of new compliance program guidelines for health care providers. Hospitals received their new rulebook in February and home-health agencies got theirs in August; thus, almost the entire health care sector is navigating uncharted regulatory waters these days. Furthermore, notes Myers, a recent federal investigation of teaching hospitals showed the perils of not keeping abreast of federal rules. Going over the books of teaching hospitals, auditors found tens of millions of dollars of Medicare overpayments-money that the hospitals were forced to pay back to the government. "Blood," says Myers, "is in the water."