The Department of Health and Human Services, Office of Inspector General (“OIG”) recently released a favorable advisory opinion, OIG Advisory Opinion No. 22-17, analyzing the proposed restructuring of financial relationships...more
The Eleventh Circuit recently clarified the standard for deciding whether a plaintiff has engaged in a protected activity for purposes of successfully pleading a False Claims Act (“FCA”) retaliation claim. In Simon ex rel....more
The Department of Health and Human Services, Office of Inspector General (OIG) recently released a favorable advisory opinion, OIG Advisory Opinion No. 22-11 (the “Opinion”), analyzing the proposed employment of an individual...more
AGG’s Government Investigations Team Insights provides periodic updates covering legal and regulatory topics.
In this edition, we analyze a recent Eleventh Circuit decision addressing False Claims Act penalties and the...more
2/28/2022
/ Anti-Kickback Statute ,
CARES Act ,
Coronavirus/COVID-19 ,
Discount Pricing ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud ,
Government Investigations ,
Healthcare ,
Healthcare Fraud ,
Infectious Diseases ,
OIG ,
Paycheck Protection Program (PPP)
On January 19, 2022, the Department of Health and Human Services, Office of Inspector General (“OIG”) released a favorable advisory opinion, OIG Advisory Opinion No. 22-01 (the “Opinion”), analyzing a proposed expansion of...more
2/15/2022
/ Advisory Opinions ,
Anti-Kickback Statute ,
Beneficiary Inducement ,
Civil Monetary Penalty ,
Customer-Loyalty Programs ,
Discount Pricing ,
Food & Drug Regulations ,
Low-Income Issues ,
Medicaid ,
Medicare Advantage ,
Medicare Part B ,
Medicare Part D ,
OIG ,
Patient Access ,
Pharmacies ,
Prescription Drug Coverage ,
Prescription Drugs ,
Remuneration ,
Sanctions ,
Statutory Interpretation