Compliance

Our continued commitment to compliance

At the time of the legal close of the merger between Patient Advocate Foundation and PAN Foundation, the organization’s Compliance Program—including but not limited to compliance with OIG Opinions and subsequent modifications and all relevant laws, regulations, and guidance—is overseen by the newly combined Patient Advocate Foundation Board of Directors.

Patient Advocate Foundation is proud of its track record of full and complete compliance with all applicable laws and regulations throughout the entire history of the organization. PAF is the recipient of the second opinion issued by the Office of Inspector General (OIG) to a charitable patient assistance program, and as such we have always understood our obligation to operate our program with the highest degree of ethical decision making, ensuring all policies, procedures and practices are designed and implemented in a manner that comports with both the spirit and intent of the OIG guidance received by the foundation over the past two decades.

Together, our commitment to compliance could not be stronger and will continue to be the foundation of our work. This commitment to compliance starts with our Board of Directors, and their oversight role has been, and will continue to be, embedded at every level within our unified organization.

Advisory Opinion adherence

Both Patient Advocate Foundation and the PAN Foundation will continue to adhere to our respective Advisory Opinions through June 2026.

• Patient Advocate Foundation Advisory Opinion #04-15 – issued October 29, 2004 (as modified)
• PAN Foundation Advisory Opinion #07-18 – issued December 19, 2007 (as modified)

Starting in July 2026 with the launch of our TotalAssist program, our unified organization will adhere to Advisory Opinion #07-18 (as modified).

Compliance has been and will remain the foundation of our work. We will continue to operate our comprehensive compliance programs for our legacy copay programs, with continued oversight from our Board of Directors.

From now-July 2026: Continued management of respective compliance programs

Through July 2026, both organizations will maintain and implement their current compliance programs. Both programs will continue to be overseen by the Board of Directors

In July 2026, we will continue to operate the best-in-class Patient Advocate Foundation Compliance Program in alignment with the TotalAssist program launch, with continued oversight from the Board of Directors.

Learn more about the current Compliance Programs:

• Patient Advocate Foundation Compliance Program
• PAN Foundation Compliance Program

From July 2026 onward: Continued implementation of Patient Advocate Foundation’s Compliance Program

Patient Advocate Foundation’s best-in-class Compliance Program will continue to be the foundation of our work, overseen by the Board of Directors and led internally by Stephanie Trunk, Esq., Partner, ArentFox Schiff, LLP.

Since the inception of its program in 2004, PAF has engaged the services of ArentFox Schiff, LLP, Washington, DC, as its compliance counsel. ArentFox Schiff are experts in regulatory compliance, specializing in compliance programs related to patient assistance programs and lead the development, implementation, and ongoing management of PAF’s organizational compliance program, as well as serve as its Compliance Counsel.

The program is designed to prevent, detect, and respond to illegal, improper, and unethical conduct, serving as a procedural framework for enhancing and monitoring compliance with applicable laws, regulations, the PAF Code of Conduct, and PAF’s policies and procedures.

We are proud to lead a compliant and comprehensive charitable assistance program that puts patients at the center.

Driven by patient need

PAF is the only charity to use data derived from the delivery of in-depth case management services provided to patients living with hundreds of unique chronic, debilitating and/or life-threatening diseases to accurately identify and define the disease funds in our program, grounded in actual demonstrated patient need data collected first-hand.

Comprehensive oversight

A Compliance Program with oversight from our Board of Directors, led by one of the most tenured top executives in the sector, Alan Balch, PhD, CEO Patient Advocate Foundation and Incoming Executive Chairman and leadership from Stephanie Trunk, Esq., Partner, ArentFox Schiff with in-house compliance staff.

Extensive combined experience

Over 40 years of combined experience operating charitable copay assistance programs, with Patient Advocate Foundation being among the first to receive an OIG Advisory Opinion in 2004.

Led by subject matter experts

The most tenured executive operational leader in the sector, Fran Castellow, MSEd., President, Operations, oversees all charitable copay assistance programs, including the forthcoming TotalAssist program.

Operational excellence

All operations have been conducted in house from day one, and more than a dozen nonprofit partners trust us to operate their own programs, with compliance at the center.