A recent settlement involving a Medicare Advantage plan should serve as a reminder that the federal Anti-Kickback Statute (AKS) is broad and far-reaching, both on its face and in practice. On July 1, 2022, the U.S. Department...more
7/12/2022
/ Anti-Kickback Statute ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Health Care Providers ,
Incentives ,
Medicare ,
Medicare Advantage ,
OIG ,
Patient Referrals ,
Settlement
The U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) on July 8, 2021, issued Advisory Opinion No. 21-08, a favorable opinion authorizing a manufacturer of gene therapy to provide...more
• The U.S. Department of Justice (DOJ) recently updated its guidance to Criminal Division prosecutors in evaluating a corporation's compliance program when making charging decisions (Guidance).
• The Guidance directs...more
5/9/2019
/ Best Practices ,
Chief Compliance Officers ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Health Care Providers ,
New Guidance ,
OIG ,
Policies and Procedures ,
Risk Assessment
• A recent federal jury verdict in Dallas affirms the U.S. Department of Justice's determination to extend federal prosecutions to healthcare arrangements involving commercial payers by utilizing the federal Travel Act, which...more
4/26/2019
/ Aiding and Abetting ,
Anti-Kickback Statute ,
Bribery ,
Criminal Conspiracy ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Billing ,
Federal Health Care Programs (FHCP) ,
Federal Prosecutors ,
Health Care Providers ,
Health Insurance ,
Healthcare Fraud ,
Hospitals ,
Indictments ,
Interstate Commerce ,
Jury Verdicts ,
Kickbacks ,
Medical Centers ,
Money Laundering ,
Out of Network Provider ,
Patient Referrals ,
Physicians ,
Travel Act