On April 14, 2025, the United States Court of Appeals for the Seventh Circuit issued a decision in a case involving the federal Anti-Kickback Statute (“AKS”) and marketing services that the court framed as an appeal...more
On September 23, 2024, Principal Deputy Assistant Attorney General Nicole M. Argentieri announced updates to the U.S. Department of Justice’s (“DOJ”) guidance relative to its Principles of Federal Prosecution of Business...more
9/30/2024
/ Artificial Intelligence ,
Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Priorities ,
Innovative Technology ,
Risk Management ,
Transparency ,
White Collar Crimes
Since October 2021, the Department of Justice (DOJ) has been implementing a variety of changes to its corporate criminal enforcement policies. These efforts all reflect DOJ’s focus on individual accountability, punishing...more
Six months from the date of closing. That’s how long acquiring companies have under the newly announced Department of Justice (DOJ) Mergers and Acquisitions (M&A) Safe Harbor Policy to disclose misconduct discovered in the...more
When the COVID-19 Public Health Emergency (“PHE”) ended on May 11, 2023, many physician groups furnishing certain medical equipment, devices, and/or supplies to their Medicare patients became in violation of the federal...more
8/14/2023
/ Anti-Kickback Statute ,
Coronavirus/COVID-19 ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Health Care Providers ,
Health Insurance ,
Healthcare ,
Healthcare Fraud ,
Infectious Diseases ,
Medical Devices ,
Medicare ,
Physicians ,
Public Health Emergency ,
Self-Referral Disclosure Protocol ,
Stark Law ,
Strict Liability
The Department of Health and Human Services Office of Inspector General (OIG) recently published a new frequently asked question (FAQ) and advisory opinion addressing how to analyze arrangements that may involve providing...more
In response to a recent Department of Justice (DOJ) request that all DOJ components write voluntary self-disclosure policies and “clarify the benefits of promptly coming forward to self-report [as] a good business decision,”...more
It’s critical for patients leaving the hospital for a post acute care (PAC) provider that the handoff be conducted well. Some facilities will be better suited to the patients needs than others, which is why the process needs...more
Announced in the Consolidated Appropriations Act of 2021, Rural Emergency Hospitals (REHs) will be a new type of Medicare provider starting January 1, 2023. REHs are meant to help address the stressed health care system of...more
On August 19, 2022, the Department of Health and Human Services Office of Inspector General (“OIG”) posted Advisory Opinion 22-16 (“AO 22-16”) to its website, a favorable opinion concluding that the OIG would not impose...more