Fun and engaging ideas for a memorable Compliance Week this Fall
It’s that time of year again – changing leaves and shorter days mean it’s the season for corn mazes, carving pumpkins, college football…and Compliance Week! While your colleagues are likely itching with excitement for the first three, would they say the same about Compliance Week?
Coming up with new and engaging programming is challenging and time-consuming, and each Fall we get asked, “How can we spice up our Compliance Week?” or, for our repeat clients, “How can we outdo what we did last year?”
This year, we’ve decided to proactively pull together our recommendations for low-cost, creative activities that build an engaging Compliance Week and share with the broader compliance community.
Before selecting activities, it can be helpful to start by aligning on a goal for the week. The Society of Corporate Compliance and Ethics describes “awareness, recognition, and reinforcement” as the core principles for Corporate Compliance and Ethics Week.
More specifically, though, what outcomes would you like to see or what behaviors would you like to reinforce? This can help focus your messaging for most impact. Consider, for example:
In many cases, all of the above are true. The important piece to remember is to not try to tackle too much. It’s better to deliver on one goal than to do some of everything and overwhelm.
Now for the fun part! We’ve compiled the list of ideas and inspiration for interactive Compliance activities across both live and virtual audiences. Consider adding incentives to up the stakes, either by offering entry in a prize raffle for participation or by awarding prizes based on a leaderboard.
Engaging Games:

Trivia with a Twist:
Creative Communication:

Plan ahead and send out announcements and save-the-dates for Compliance Week and your planned activities. Consistency is key! One way to help your audience recognize Compliance content is to create Compliance Week 2025 branding or a logo to help build up the hype!

Have other fun ideas to get your teams in the Compliance Week spirit? Feel free to connect and share with us!
Potomac’s Internships Provide Opportunity to Make a Lasting Impact
Each fall throughout college, I’d reconnect with friends I hadn’t seen in a few months and ask, “how was your summer?” I always expected to hear about interesting new experiences, changed perspectives, brains stormed and oceans boiled, etc.
Instead, I usually heard some version of the following: “Oh it was good, I had an internship. It was pretty chill, a little boring – I took notes for a few meetings and had a small project that lasted about a week – otherwise, I mostly just showed up.” I spent my college summers working at a youth camp, so I always said “nice, that sounds relaxing!” while thinking “wow, that sounds terrible!” It wasn’t until I got to Potomac that I realized an internship can be so much more than the tedium reported by my friends.

Every year, Potomac invites a bright group of rising college seniors to contribute fresh perspectives, work on engaging, self-driven projects, and test drive a career in management consulting. Our summer interns work at our office in Arlington, just outside Washington D.C., learning the ins and outs of the life sciences industry and developing healthcare compliance experience. Through Potomac’s internship program, they get the chance to gain insight and exposure to client‑facing work while also learning about the inner workings of a consulting firm.
Potomac’s intern program team designs the summer experience around three mutually-reinforcing elements:
1) Client Tasks: Meaningful exposure to real world experience
Rather than staffing our interns solely on menial, day-to-day operations work or conceptual projects that will never see the light of day, we introduce our interns to Associate-level client tasks with managers who provide authentic, useful feedback. Typical tasks include retrospective auditing, drafting policies, and creating communications for clients. This work helps identify the intern’s strengths and clarify areas of interest quickly. Some lean into data analysis. Others shine in writing or working in PowerPoint. Everyone gets enough variety to learn and explore what they enjoy and where they want to grow.
2) The Individual Project: Own a piece of Potomac
Each intern develops and presents a standalone project that advances a firm resource. They take a deep dive into Potomac’s capabilities and ways of working. This summer’s projects included developing AI-centered resources for Potomac’s Launch Pad policy toolkit, synthesizing improvements to our Retro Monitoring framework, and exploring uses for a new eLearning tool. Through the individual project, interns get the opportunity to build project management experience, show off problem solving skills, and learn to present their own recommendations. At the end of the summer, interns can point to the workstream they’ve owned, see a finished product, and say, “I built that.”

3) The Team Project: Learn together, build together
Potomac’s approach to hiring requires individuals that can not only contribute independently but also work well as a team. Our HR leaders seek to build a well-rounded group that can share credit and solve problems together. Throughout the spring, our management team prioritizes a key project for our interns to work on together based on the company’s annual goals. This summer, our interns built an externally-facing SharePoint site that organized Potomac’s intellectual property into a format that can be viewed during sales meetings and mimics the way a client could roll them out. The team worked closely with senior leadership to define the scope, set the requirements, carve out roles, and align on a clean information architecture. This year’s finished product demonstrated the impact that can come from a cohesive, focused group of interns.
What Can a Potomac Intern Expect?
Potomac interns learn how compliance teams operate and why it matters to life sciences companies. You will work on real projects with immediate impact. You will write, analyze, iterate, and present. You will get frequent feedback from experienced managers who want you to succeed. If you like solving messy problems, ask good questions, believe feedback is how you learn, and finish what you start, you will thrive here.
Potomac is looking for current juniors for Summer 2026 internships who can bring curiosity, initiative, and excellence to the world of healthcare compliance. If that describes you, submit an application today!
A Note for Employers
For our clients and friends who run or are evaluating an internship program, consider this three-part model. Develop a clear, learning-oriented structure and balance exposure to future job-related tasks with special projects. Add frequent feedback throughout the process. This generates a concrete impact on your organization and meaningful positive outcomes. You will have an opportunity to evaluate future candidates based on individual accomplishments and whether they can operate well as part of a team.
Over the last year, I’ve been on at least five calls with companies where I’ve said, “I don’t think you need Potomac’s support, save your money for now.” Each time, the companies have been more than a year away from launching their products and are already asking about deploying a software solution to meet their Sunshine Act reporting obligations.
Don’t get over sold… if you’re more than a year away from launch, you do not need to purchase a software solution for transparency reporting. That’s far too early. Don’t rush.
FDA approval is a milestone worth celebrating, so enjoy it! But it also exposes your company to a whole new set of compliance obligations. If your product is reimbursed by Medicare, Medicaid, or CHIP, you have a Covered Product and are very likely on your way to being considered an Applicable Manufacturer under the Sunshine Act.
There’s some good news: designation as a new Applicable Manufacturer qualifies for a 180-day grace period from when the product becomes first available for purchase before manufacturers are obligated to start CMS data capture. Therefore, the earliest payment that you’ll report to CMS is at least six months after launch.
Keep in mind that many of the states aren’t quite so accommodating and do not have the same 180-day grace period. So, depending on the industry (rules vary between pharma and device) and states in which you operate, you may have state reporting obligations at launch.

Capturing and reporting data for Sunshine reporting may seem like a daunting task but it doesn’t have to be a full-time job and you don’t need complicated or expensive systems to fulfil your reporting obligations. I’ve helped numerous companies launch their transparency programs and each company faces a different set of challenges when launching. Following these steps can help you better prepare:
First, critically examine your internal infrastructure and determine if your existing framework has the capacity to capture appropriate data. Conducting a comprehensive spend inventory will help you prepare for data capture and the launch of a transparency system. A spend inventory offers clear insights into your spending and about the process you plan on using to capture the data. This doesn’t mean you always need to integrate an IT system; in many cases, Excel works just fine.
Not all life sciences companies are the same and neither are their source systems! For new companies, the first system I recommend focusing on is your highest-volume system, usually the T&E system (most frequently Concur in the life sciences industry). Implementing a tool to allow users to search for HCPs within your T&E system instead of manually entering information is one of the best investments you can make in the early stages. It will save you and your team headaches and time during reporting. Beyond T&E, it’s helpful to have a plan on how you will capture other areas of spend such as ERP direct payments, third-party vendor payments, reprints, and any other area identified in Step One.
For most companies, investing in a flashy new system or hiring full-time support can be time-consuming and costly when resources are limited and there aren’t enough hours in the day to complete everything needed for launch. In my experience, most companies simply need to analyze their existing infrastructure and procure supplemental resources or external assistance to fill the gaps.

For companies with a sales force of 10 representatives or fewer and minimal reportable transactions, your entire CMS reporting can likely be handled via Excel. There are also companies that focus on manual reporting options at extremely cost-effective prices.
Companies with 10-50 representatives often have enough complexity to need real infrastructure but not enough to justify a large technology investment in a SaaS solution. Hiring a managed services firm for outsourced support is an efficient and simple approach to fulfilling reporting obligations. Managed service firms help companies with limited volume navigate data management. For example, my team at Potomac uses our in-house aggregate spend database, WholeSum, to collect, remediate, and report your data without the overhead and effort associated with implementing and running SaaS Transparency solutions.
For higher volume companies, reporting can be streamlined by using SaaS solutions that automates data collection from various sources, generates reports, and provides the company with greater access to their data for monitoring and other purposes. However, a SaaS system does not necessarily require a full-time transparency resource. There are companies, including Potomac, that provide fractional transparency team support to allow your team to focus their attention on other areas of your compliance program. Transparency experts are typically the busiest during “reporting season,” the period from January-March before Open Payment reports are due. But there is often less to do throughout the year, making it difficult to justify a full-time headcount.
If your company has over 200 representatives, you will likely need to build out a larger-scale transparency program that likely includes licensing a SaaS solution and hiring a full-time resource. There are still decisions to be made about the seniority level of the employee and whether they are primarily leading the program with support from others or with a data steward who is an expert at getting data into the SaaS system, remediating errors, and analyzing data for accuracy.
Required reporting begins after the 180-day grace period between March and July 1 of the year following approval. With no need for retrospective reporting under the Sunshine Act, the grace period gives you the time to build a strong Transparency Reporting foundation.
This is a time to practice collecting data, fix processes, and refine your approach. Use this time wisely and treat it as a test run. Use real data and confirm if what you collected was complete.
Was the process working? Are there areas for improvement?
Use this grace period to find issues now instead of right before reporting deadlines.

Getting FDA approval for your first product is exciting! I know that comes with pressure and that pressure is real. But launching a transparency program doesn’t have to be a lonely (or expensive) sprint. The best programs are the ones that start simply, build steadily, and fit the solution to their company. Don’t get oversold…
When life sciences compliance teams build monitoring plans, they often start with a broad list of activities such as speaker programs, advisory boards, and charitable contributions.
But here’s the problem: these activities are often conducted in different ways, resulting in various layers of risks depending on the way it’s being done. Consider speaker programs as an “umbrella activity” with those layers underneath. Under the umbrella might include live programs, unbranded disease state programs, programs related to one therapeutic area versus another… the list goes on. When a compliance officer begins to consider the variations of each umbrella activity, it might lead to the question of how to deploy monitoring resources to address the highest risk activities.

At first glance, it might seem like your compliance team should start with regulatory risks like kickback or off-label promotion when developing a monitoring plan. But Potomac has found it’s more effective to begin by understanding the full scope of what your teams are doing. Listing out activities serves as the foundation for identifying risk and can complement your compliance risk assignment to directly align to your monitoring plan.
Once you have your list of “umbrella activities”, ask yourself and your team: Are the risks different, even within the same type of activity?
The answer is almost always yes. And that’s where segmentation comes in.
Segmentation means breaking down your umbrella activities into smaller categories that reflect different risk profiles. That could include:
For example, live speaker programs for a newly launched therapeutic area might require closer scrutiny than a mature brand presenting data on a new indication.
By segmenting, you’re no longer saying, “We’ll monitor 10% of speaker programs.” You’re defining which ones, why, and how often based on a defensible risk rationale. Segmentation becomes increasingly important for mid-size and large life sciences companies considering the high volume of business activities. As an added benefit, this approach helps ensure your monitoring team work efficiently while focusing on the most critical compliance risks
The graphic below illustrates how a broad activity like “speaker programs” can be broken down into manageable, meaningful segments. Applying multiple layers of segmentation allows you to hone in on the most relevant risks and prioritize with greater precision.

Even if you don’t have exact volumes while segmenting your activities, that’s okay. Use historical data, your annual needs assessment, annual budget plans, and business strategy to make informed estimates and update your plan as you learn more about activity volumes.
Once you’ve identified your high-risk segments, build a plan that balances:
Then make segmentation and risk review an annual exercise. Risks shift. Controls evolve. Revisiting your segmentation regularly keeps your monitoring plan relevant and proactive.
With an organized, segmented approach, your monitoring plan becomes more than just checking the box on compliance requirements. Your compliance program is becoming more effective, turning monitoring into a tool that helps you understand and gain visibility into your business activities, detect and mitigate risks, and strengthen your controls over time.
So, the next time you revisit your compliance program plan and monitoring goals, don’t just ask what you need to review – ask how you can segment smarter to focus on what matters most!
“Umbrella activities”, segmentation, selections – oh my! Potomac is excited to cover the key concepts of segmented monitoring plans at PCF 2025.
Join me alongside a panel of pharmaceutical and medical device industry experts to learn more about building a smarter monitoring plan.

A full year has passed since my last article, though not for lack of ideas or industry developments. I kicked off last year with a goal to write more. For a while, I did just that—then business picked up… and before I knew it, a year had flown by.
Now that the dust has (momentarily) settled, I wanted to share what is current in our latest Currents.
I thought the best place to start was musings from the latest Pharmaceutical Compliance Congress (PCC) where AI was all the rage…
From the main stage, my friend Daryl Kreml provided an anecdote very similar to our experience with AI. With apologies for anything I misattribute, Daryl explained how he asked GenAI to develop a policy on funding for independent copay foundations. The first draft was appropriately formatted and well-organized, but lacked specifics to help control risk. Like someone new to the industry writing a first draft. A second prompt got closer, more akin to an experienced compliance professional. A third prompt focused on adding in controls from specific DOJ settlements, prompted based on Daryl’s own bank of knowledge and experience. On the third try, the GenAI pulled together a policy that could go forward more or less unedited.
It took 20 minutes, because of 20 years of experience.
This was one of my favorite discussions (from late at night at the hotel bar, where the best conversations take place). If experts do it best, how will the next generation learn to be experts once AI is everywhere? How do we ensure they develop the required knowledge and judgment to be elite users of AI?
These are difficult questions and while I don’t have the answers I thought I would share my thoughts on some key parameters.

On Tuesday, three members of our Class of 2026 internship program will join us for the summer. To put things in perspective, they were about 3 years old when the first iPhone came out. They cannot remember a time when they have not had access to an incredibly powerful computer in their pocket. While some of us Gen X’ers (and older) remember the days before the Internet when we had to memorize facts and dates, an entire generation has grown up asking Siri for any fact or figure (or DOJ settlement). Now Gen AI provides not just the knowledge of the Internet but a very strong helping hand. Our job as leaders is to provide our teams with structure to effectively use these powerful tools.
In the absence of memorized knowledge, we need to teach our teams to prime the AI by adding a research step to the queue of prompts, ideally before diving into the task. For example, before starting a policy on co-pay foundation funding, ask the AI questions about settlements and risks.
Prompts like:
The results of this series of queries can be viewed here.
The most common question we heard was, “Do you think AI is going to take my job?” People across the country are thinking about this, not just Compliance professionals.
Compliance Programs are ultimately about behavior change. AI can help develop policies, procedures, communication, and training. AI monitoring engines can point out data outliers for further evaluation. But Compliance is more than just policies and training—it’s about persuading people to do the right thing. And monitoring is more than running algorithms to identify risk. It’s the ability to understand nuance and identify root cause(s) of observations to be able to make systemic changes, not “gotcha” compliance programs. We’re finding that meaningful change still requires interpersonal, human-to-human connections.
So here are some of the areas we think are unlikely to change soon and where we are focused right now. For our in-house colleagues and clients, these are also areas that are likely to remain AI-free for the intermediate time-period and may be good areas to focus career paths, especially for those that are earlier in their careers:

If last year taught me anything, it’s that writing every month may have been an overly ambitious goal. This year, we’ll be mixing it up. You’ll hear from others across Potomac, with other voices joining the conversation—and likely, a little help from our friend ChatGPT.
Hamlet-Inspired Rationale for the Thoughtful Use of AI
If you took a drink every time you heard the word “AI” at the recent Pharmaceutical Compliance Conference (PCC), you’d have been drunk before 10 AM. It seemed as if every presentation mentioned “AI”, including several exclusively focused on the topic.

Many of the discussions centered on whether companies should use AI.
In one corner were those emphasizing the impact AI can have in streamlining manual tasks and advancing data analytics. Oversimplified, no need to hire, AI can do that.
In the other corner were those claiming that AI can never (or at least not in the near future) replace the human component of compliance programs.
The naysayers added that AI creates a myriad of new risks for the organization including access to confidential information, privacy concerns, and potential for error and put simply, needs to be approached with extreme caution.
With apologies to the Bard, I believe “To AI or Not to AI”? is the wrong question. Like the debate on rules vs. values-based compliance programs, the answer is both.
Generative AI is here to stay. And for any who refuse to approach it head on, I cite Hamlet’s Queen Gertrude — “the lady doth protest too much, methinks.”[1] Let us not be like Hamlet and allow our conscience to make cowards of us all. Instead, let’s focus on three critical questions:
I conversed with ChatGPT to flesh out these questions and found it immensely helpful. All text in blue was drafted by ChatGPT (often edited for brevity). The subsequent Hamlet quotes were largely identified by ChatGPT — including one from Henry IV. More on that later…
[1] Please note, gendered language used throughout this piece is specifically from Hamlet, written in ~1600).
“Though this be madness, yet there is method in’t.” – Polonius
First and foremost, AI — and technology more broadly — should be used to automate manual processes. At Potomac, we often talk about the importance of sharpening your saw as conveyed in the 7 Habits of Highly Effective People. Undo the madness of performing the manual activity, identify the consistent method to it, and automate it. Technology is great at this.
There are many use cases for compliance professionals. Some are easily identifiable and have been available for years, such as aggregate monitoring and automated sanction screening. Others are newer, such as using tools like Microsoft Copilot to reduce formatting time. I cringe watching transparency professionals look up HCPs one at a time in the NPPES registry (if you do this, please, please reach out to me to stop that madness).
And as natural language processing continues to improve, there will be a growing host of automatable functions. For example, highly educated (and compensated) human beings in the Medical Affairs function frequently review doctors’ résumés to “tier” them as part of a “fair market value” assessment. In the future, this first pass could and should entirely be handled by machines.
“There are more things in heaven and earth, Horatio, than are dreamt of in your philosophy.” – Hamlet
The potential of generative AI in ethics and compliance transcends our current understanding, offering opportunities for innovation and advancement that may surpass our wildest imaginations.
Generative AI is exceptional at expanding initial idea generation. In Hamlet, the “play’s the thing.” When dealing with AI, you could say “the prompt is the thing.” The key is knowing where and how to prompt the discussion. Because Generative AI is best when building on existing creative ideas. It becomes an instant group brainstorming session. If you have an inkling of an idea, ask the AI for more. See what it says, and then ask for more details. It’s like having colleagues working with you on a whiteboard.
I don’t know about “surpassing our wildest imagination.” Maybe I haven’t mastered prompts. But in building this piece, I initially asked for Shakespeare quotes to help support this piece. When it provided an example from Hamlet, I pivoted and asked for more quotes from Hamlet and how to tie those quotes into my central theme.
If Hamlet is not your thing, ask generative AI for lyrics from Taylor Swift songs that relate to your latest Code of Conduct training. Or famous movie quotes…or…. Like any good brainstorming session, you’ll get good ideas and bad ideas; the key is to zone in on what you want to keep.
“Something is rotten in the state of Denmark.” – Marcellus
I’m feeling a little “unmotivated” to write this one.
I submitted the following prompt to ChatGPT, “Can you tie the concept of motivation to starting something new with the quote “Something is rotten in the state of Denmark.” Aiming for something centered around how hard it is to get going when you are feeling “rotten” or unmotivated.“ (Note: I have edited the text below for length by deleting redundant paragraphs).
“Something is rotten in the state of Denmark” serves as a poignant metaphor for the internal state of disarray or discontent that can hinder our motivation to embark on new endeavors. Just as the characters in Hamlet confront the pervasive sense of corruption within their society, individuals grappling with feelings of disillusionment or stagnation may find it challenging to summon the motivation needed to initiate change or pursue new opportunities.
However, just as Hamlet ultimately confronts the corruption within his kingdom and takes action to restore order, individuals can overcome their internal barriers and find the motivation to initiate change.
Staring at a blank sheet of paper is hard. Generative AI can be a useful starting point to get a first draft moving. It need not cover everything but can help overcome that initial inertia. Especially when you are feeling unmotivated to tackle the corruption within your kingdom.
“Doubt thou the stars are fire, Doubt that the sun doth move, Doubt truth to be a liar, But never doubt I love.” – Hamlet, as read by Polonius
“Here’s a list of 30 additional Hamlet quotes… 26. “The better part of valour is discretion.”
To which I immediately asked ChatGPT where I could find that quote in Hamlet. It responded:
“The better part of valour is discretion” is a famous quote from Shakespeare’s play “Henry IV, Part 1,” spoken by Falstaff in Act 5, Scene 4.

For those looking to use Generative AI to help provide compliance answers to complicated questions via chatbots and similar tools, I have serious concerns. While natural language processing is improving, there is still a tendency by GPTs to “hallucinate” and guess at responses even when facts are straightforward and easily verifiable. It’s obviously harder when different words are used in the questions than those specifically stated in the policy or training are fed into the system. There is a real risk of providing inaccurate guidance.
Others have covered this topic much better than I can. Maybe these hallucinations are the ghosts of Hamlet’s father. Over time, I imagine AI hallucinations will improve, potentially immensely. But right now, answers unchecked by human eyes can be troubling. “Doubt truth to be a liar.”
“Brevity is the soul of wit.” – Polonius
Polonius’ wisdom reminds us of the importance of clarity and succinctness in communication.
GenAI ≠ “Clarity and succinctness.”
A friend and colleague of mine (who inspired this article) mentioned at PCC how much bad writing we’ve fed into the AI engine. It has not learned to be concise. Edit the output.
“The readiness is all.” – Hamlet
ChatGPT did a good job with this one. I’ll let it explain:
Hamlet’s profound realization before the climactic duel with Laertes speaks to the importance of preparedness. When it comes to automating repetitive tasks with AI, readiness in terms of data preparation, infrastructure setup, and organizational alignment is crucial for successful implementation.
For those looking to use AI to develop risk-based insights, I’ll remind everyone of the importance of data quality: garbage in, garbage out.
And there must be organizational alignment on how and when to use AI securely to prevent loss of confidential information, protect privacy, and be net beneficial to compliance efforts.
“This above all: to thine own self be true.” – Polonius
Polonius encourages Laertes to prioritize authenticity and self-awareness…to maintain one’s integrity and moral compass…
Human interaction plays a crucial role in fostering trust and building relationships, especially in compliance investigations and audits….
Ethical dilemmas and complex compliance decisions require human expertise to consider factors such as intent, mitigating circumstances, and ethical implications…
Humans are better equipped to communicate findings, address concerns, and collaborate with stakeholders…
Human oversight is essential to ensure that AI systems are deployed ethically, responsibly, and in alignment with organizational values and regulatory requirements.
Our role as compliance professionals must expand with AI. We need to shift our own focus from the monotony of following the black and white “rules” towards the gray area of “values.” We need to step up our game and show thoughtfulness in evaluating complex scenarios. Only humans will be able to solve new and evolving compliance concerns that cannot be fed into the algorithms.
The job for building and enforcing the company’s culture will remain the job of the Compliance Officer. At the heart of that is our individual relationships with people. AI will not replace that.
Reflections on Potomac’s First 18 Years
Potomac turns 18 today. For Jewish people like me, the number 18 has special meaning. It stands for “life.” As Tevya sings in Fiddler on the Roof, Jews say “L’chaim!” which generally translated means, “to life.”
When I was in second grade, we learned Roman numerals in school, which was important if you wanted to read Super Bowl logos. My local team, the defending champion (at the time named) Washington Redskins, got crushed in Super Bowl XVIII to the hated (at the time) Los Angeles Raiders. All of us in the DC-area knew XVIII meant 18.
Ancient Hebrews also used letters to represent numbers. Each of the letters in the 22-character Hebrew alphabet represented a unique number. Rather than using five characters to represent 18, you only needed two.
The word chai (life) is made up of two letters: ח ( “chet” with a “kh” sound as in the guttural German pronunciation of “Bach”) is the 8th letter of the alphabet so = 8. And The letter י (pronounced “yood” like yellow) is the 10th letter of the alphabet so = 10. These two letters form the word chai and add up to 18. This is why the number 18 is associated with life.


While L’chaim generally means “To Life,” the “L-” sound up front is translated as both “to” and “for” in English. The word chaim is the plural of chai, so is more accurate as “lives,” not just one life. Put together, “For lives” is just as accurate as “to life.”
Some have claimed that l’chaim “expresses the idea that no one can live life alone. We all need someone else. There’s no point in toasting to life alone.” It’s not about one life – it’s for lives.
For the last 18 years, I have had a hard time separating my life from Potomac. I’ve admitted to my team on many occasions that I often take criticisms of Potomac as personal criticisms. When something goes wrong, I wonder what I could have done differently to have prevented it. On the external side (especially in the early years of the company) we worked hard to brand Potomac as being unique from “Jon’s company.” But personally, I felt like there was little separation between Jon’s life and Potomac’s life. It seemed like one life.
But there is no point in toasting to life alone. We all need someone else. And to get to 18 years, I’ve had the benefit of working with many, many hard-working and dedicated people. We’ve had and currently have an incredible team.
I am truly grateful for the more than 100 people who have worked for the company, whether as employees, independent contractors, or our third-party support partners. I am proud of the relationships built over the last 18 years. I have danced at our employees’ weddings, met their new babies, and wished others well as they left us for business school or other pursuits. In several cases that included becoming our future clients.
I am especially appreciative of our senior team, who have worked tirelessly to embed our values of integrity, accountability, professionalism, and discretion into all that we do. Many of our team members have been with the company for more than 10 years. We would not be the company that we are today without their unwavering dedication.
The picture on the left below is from 2016 and of the 11 people pictured (besides me), 6 are still current team members—from left: Carla-Marie Ulerie, Adam Oakley, Meredith Swartz, Michael Young, Dan Koerner, and Graham Rich. I’m proud of that longevity.

We’ve had the privilege of working with over 150 companies and thousands of people. Over time, I’ve watched as our client leads have gained promotions and changed roles, taken on wider responsibilities, or in some cases, opted to downshift and/or retire.
Over 18 years, you get to know some of the people at those clients very well. We work hard to become an extension of our clients’ teams and, in some cases, like our co-workers, our clients become our friends. I’ve heard stories about weddings and divorces, babies being born and kids going off to college, exciting vacations to far-away places, and debacle home renovations. This past month, one of my earlier and most fun-loving clients passed away relatively suddenly. That one touched a nerve – wasn’t prepared to add funerals to this list.
About 10 years ago, a client described her company as a “gangly teenager” that was going through the awkward phase that many teenagers do. I hadn’t really thought about companies maturing in a similar way to humans but the more I thought about it, the more I realized it was true:

And now, we’re 18 and Potomac is supposed to be an adult. In some ways, I feel like I’ve been preparing for this day for a while, getting my child Potomac ready to go off to college. Especially over the last year, when we’ve pursued a project appropriately named Operation Evolution. Part of its focus is to make the business less dependent on me. This included changing my role to allow the company the space it needs to grow and mature. And give me time to write these types of articles. 😊
Meanwhile, our senior team has stepped up and taken on additional responsibilities –ranging from Finance to HR to Business Development. The transition has been hard at times, but we are evolving and making progress.
Evolution is necessary to sustain life (and business). There will be more change to come as we work through new structures, processes, and approaches to remain a sustainable, long-term business. We are committed to maintaining the level of excellence and teamwork that has marked the first 18 years of our life.
I personally look forward to also evolving my role back to where it started. Completing the circle of life, if you will. In the months ahead, I am hoping to spend more time working directly with our clients. I love wrestling through their most complicated issues, working together to make our industry more ethical. And ultimately safer for the lives of patients.
In closing, I pledge to continue to work to make a difference in the lives of our team members and our clients. We will continue to be a great company that people want to work for and work with for the foreseeable future.
L’chaim. For lives.
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As a follow-up to my prior post on goals, I wanted to take a step back and focus on how to achieve your goals. The key is to have a plan. It sounds simple and obvious, yet it’s so often overlooked. As Antoine de Saint-Exupéry, author of The Little Prince once said, “a goal without a plan is just a wish.”
To most, planning is about as exciting as paying your taxes. Which reminds me of one of my all-time favorite Homer Simpson scenes, as quoted at left (see longer clip here).
In the clip, while Krusty is waiting in line to mail his taxes, he is asked why he waited until the last minute. He responds, “because I’m an idiot.”
We’ve all been that idiot – and always say “next time, I’ll plan ahead.”

Dale Carnegie once said, “An hour of planning can save you 10 hours of doing.” I personally think Carnegie undersold it. He only focused on you – i.e., the person doing the planning. But most projects involve other people, often very large teams. That hour of planning can easily save 10 hours per person. Which makes the potential return on investment of planning exponential.
At Potomac, we teach a project management framework called Think-Plan-Do for project management. It’s important to note: the thinking needs to come first. Understand your goals, objectives, and what you want to accomplish. Have a clear vision about what the end looks like.
But the critical part for moving from vision to reality is the plan. How will you achieve your objectives? What steps do you need to take? Who else should be involved?
Not all plans should be the same. I think this is one of the major areas where people struggle. To get your plan “just right,” you need to match the energy you put into developing the plan to the magnitude of the task. Planning can be as basic as jotting down the roles and responsibilities and needed steps.
When I decided I wanted to write more, I made a list of a few ideas for topics. Similarly, when I start writing, I draft a basic outline and some key themes/quotes that I want to cover. It’s a quick plan and easy to implement.

There are a handful of people who can take a small project and turn it into the moon landing. They map out detailed RACI grids and build out Gantt charts showing every step. They involve a multitude of stakeholders wanting to please everyone (or alternatively out of fear of excluding someone).
These plans overwhelm teams with specifics and often lack practicality—such as needing to gain consensus from a very large team or trying to meet best-case timelines. Any change to the plan creates tremendous work. Eventually, the maintenance of the plans becomes as time-consuming as accomplishing the task itself. Paradoxically, nothing gets done.

More common than the over-planner is the under-planner.
We’ve all seen the busy executive whose actions are best described as “Ready-Fire-Aim.” They trade thoughtfulness and deliberation for decisiveness. While there are many books and consultants espousing this belief, I believe this scattershot approach often leads to focusing on the wrong priorities; going through process steps out of order; and ultimately, increased error, cost, and overall frustration.
Don’t compound the problem by mimicking the behavior.
As an economics major in undergrad, I slip into econ-speak from time to time. And while my use of economic vocabulary frequently elicits eyerolls from my family (not to mention my friends, clients, co-workers…), please allow a small pseudo-economic digression.
When people think about goals, I like to think of those as the demand side. They are focused on outcomes – what do you want to get/achieve?
But too many people neglect the “supply side.” This is how your objective will be achieved. What are the internal resources, budget, and amount of time available to accomplish the task?
The key to a good plan is to evaluate whether it’s achievable given the allocated resources. And if it’s not, update the plan until it feels doable.

Mike Tyson famously said, “everyone has a plan until they get punched in the mouth.” While the thought of getting hit in the mouth by a 1980s era Mike Tyson seems scary as hell, his opponents were, after all, professional boxers. They should have included getting punched in the mouth as part of their plan.
I try and keep the Tyson quote top of mind. The more critical the objective and for any longer-term plan, it’s best to expect to be punched in the mouth. Stuff will go wrong, priorities will change, there will be employee turnover, reorganization of the business, etc. You never know what it will be, but it’s best to give yourself some cushion. And then be flexible to adjust as inevitable obstacles come up.
If you liked this piece, please check out our new “Currents” section of the Potomac website. If you have feedback on this topic (or others), please reach out to me on LinkedIn or via email at jwilkenfeld@potomacriverpartners.com.
My intention in writing these pieces is to connect with my network — many of whom are life science compliance professionals — while also trying to apply some general business lessons from running Potomac to those who are not. Where relevant, I’ll add a separate “Compliance Corner” to these pieces where I will cover topics specific to Compliance professionals that aren’t relevant to others.
At Potomac, we’re often asked to advise Compliance teams on how to develop their plan — or as we like to call it, their Compliance Roadmap. Ideally, the plan should start with a risk assessment.
Shameless plug alert – I will be leading a workshop on this at PCC 2024 with David Ryan of Ardelyx.
The results of the risk assessment should inform which areas need enhancements in the controls (i.e., enhanced policies, training, communication) and which need validation of whether the controls are working appropriately (i.e., auditing and monitoring).
The overall Compliance Plan can then be broken down in more detail in its three primary offshoots: Documentation, Training & Communication, and Auditing & Monitoring.

This methodical approach provides a solid foundation for achieving an effective compliance program. The result is a clear roadmap with actions to complete each quarter. This helps dramatically reduce stress within employee teams and has the added benefit of reducing cost as you avoid fire drill pricing and staffing from your partners.
To achieve your compliance goals, make sure your plans are fit-for purpose, balance supply and demand, and have enough built-in flexibility, just in case you get punched in the mouth.
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I failed to achieve one of my “SMART” objectives for 2023. Yet, I still fulfilled my intended goals.
The difference lies in the meaning of “goals” and “objectives” and the importance of articulating what you want to happen, as opposed to getting caught up in the measurement.

Image credit: Jennifer Burk on Unsplash
As we reach the new year, many people and companies right now are thinking about New Year’s resolutions and their overall goals. Many experts will talk about how goals need to be SMART. This is based on a framework initially developed by George Doran in an article in Management Review in 1981:
I read the original Doran article for the first time this past week. While I’ve heard the term “SMART goals” for years, Doran used the term “SMART” to define corporate “objectives.” Without knowledge of the original Doran terminology, that is the term we’ve used at Potomac as well. We encourage Potomac employees to identify their goals and think about the best path forward to achieving them using a
framework that looks something like this:
My personal example:
Early last year, coming off shoulder surgery, I was concerned about its impact on my health. I knew many of my preferred exercise activities were now off-limits, including cancelling a planned ski trip with friends.
I wanted to ensure I stayed in shape, so I decided I wanted to walk more. I’d also been reading about the mental (and physical) health benefits of being outdoors for some portion of the day. I decided I wanted to spend more time outside. Lastly, since I often sit at a screen for much of the day, I thought that quiet time by myself would be beneficial for me and Potomac.
Goals

I started 2023 by walking my neighborhood before work. I didn’t do it every day, but most. I’d also try and go for a longer walk/run on weekends. After a couple of months, I looked at my iPhone’s Health app and saw I was averaging 3,000 more steps than 2022. Being a math geek, I realized that would be more than 1,000,000 steps over the course of the year. I thought that would be really cool! 1 million more of anything sounded like a huge accomplishment.
I did some more math and to get to 1,000,000 more steps, I needed to average 2,740 more steps per day.
I felt that was hard, but achievable and led to my SMART objective:
| Objective | SMART Objective |
| I am going to regularly walk my neighborhood on days with no commute | I will walk 1,000,000 more steps in 2023 than 2022 (as measured by my phone). |
The Result:
The 3,000+ pace was tough to maintain. During the summer, I found it harder to keep up my walking habit, especially on weekends. By autumn, the average was down to 2,500 steps so I figured out how much I’d need to increase my walking to get to the 2,740 per day pace. I tried – but had a hard time increasing activity to the needed pace and remained flat throughout the Fall. By the end of October, I knew I was going to fall short.
As the year approached the finish line, with my shoulder now fully healed, our family went on a ski trip. I managed to ski 6 days and got the most exercise of any week I had the whole year! And all of it was spent outdoors.
Yet, my phone (correctly) didn’t count any of my skiing as “steps.” By December 27, I was down to 2,445 more steps per day than 2022, the lowest it had been all year. Multiply that by 365 and you get 892,425 more steps. I had failed to hit the 1 million step objective by more than 10%.
The Result, Part 2:
I am “goal-oriented” and don’t like missing objectives. It would be easy for me to dwell on being 100,000 steps short of my objective. But I was able to flip my mindset and focus on the original goals: I had exercised more, spent a lot more time outside, and had time to quietly reflect.
| Goals | Achieved? |
| I want to exercise more. | |
| I want to spend more time outside. | |
| I want to spend time by myself (e.g., thinking, listening to music/podcasts). |
It was during one of the walks that I came up with the idea to write this article. Keep your priority
focused on the outcome that you want to achieve, not the measurement.
Epilogue: 2024 Goals:
I am very much still working on how I want to implement these (more on that later), but I’ve come up
with a few goals so far for 2024.
I decided to start with this piece. I hope you’ll join me as I start my walk toward achieving my 2024
goals. Have a Happy New Year!
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