The Department of Justice continues to incentivize companies to engage in conduct that proactively demonstrates a commitment to operate in compliance with applicable laws and regulations. Building on the implementation of...more
In a much-welcomed step by the defense bar, on March 28, 2023, the United States Court of Appeals for the Sixth Circuit became the second federal appellate court to hold that "resulting from" under the 2010 amendment to the...more
On December 9, 2022, the U.S. Department of Justice's Antitrust Division and the Office of Inspector General of the U.S. Department of Health and Human Services (HHS-OIG) entered into a Memorandum of Understanding (MOU)...more
The Department of Justice (DOJ) recently recently made revisions to its corporate criminal enforcement policies that provide useful insights to corporations and their executives regarding establishing policies and procedures...more
On July 26, 2022, the United States Court of Appeals for the Eighth Circuit held that "resulting from" under the 2010 amendment to the Anti-Kickback Statute (AKS)1 requires the government to prove that "but-for" the illegal...more
The Eliminating Kickbacks in Recovery Act (EKRA), a law that became effective in October 2018, extended federal kickback prohibitions to services provided by recovery homes, clinical treatment facilities, and laboratories...more
On January 28, 2022, the U.S. Department of Justice (DOJ) announced its indictment of four owners or managers of home health care agencies for allegedly violating federal antitrust laws by conspiring to fix the rates paid to...more
Over the course of 31 days from September 9 to December 2, I participated in a complex and document-intensive contested case hearing before an administrative law judge – entirely by WebEx. Seven lawyers represented the 26...more
Introduction - In the challenging world of COVID-19, state executive orders governing day-to-day business operations across industries have become commonplace. While traditional investigations may have slowed as regulators...more