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OPINION: Proving structural compliance failure

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Photo: Atlantide Phototravel/Getty Images

Why every compliance investigation should begin with antecedent structural inquiry.

Most compliance investigations begin in precisely the right place. A complaint is received, an adverse event occurs, or a regulator raises concerns. Investigators gather the relevant documents, review policies and procedures, interview witnesses, reconstruct events, and determine whether institutional requirements were properly followed.

Every compliance investigation seeks the truth. Yet

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