Michael Peregrine was quoted by BNA’s Health Law Reporter (February 11) concerning the impact that changes to the federal sentencing guidelines could have on the compliance programs of hospitals and health systems. Mr. Peregrine said the changes emphasize that “the definition of what constitutes an ‘effective compliance plan’ … remains living, breathing and subject to periodic modification.” He noted that some elements of effectiveness include a strong document retention program and a direct compliance officer reporting relationship to the board of directors. Mr. Peregrine added that the guidelines also cite self-reporting, cooperation with authorities and restitution of damages as desirable responses after an organization detects criminal conduct.