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Audits Civil Monetary Penalty

WilmerHale

2024 CMS Audit and Enforcement Report

WilmerHale on

On July 15, 2025, the Centers for Medicare & Medicaid Services (CMS) released an Audit and Enforcement Report summarizing its annual Medicare Advantage (Part C) and Prescription Drug (Part D) program audits and enforcement...more

Buchalter

New Year, New Rules: Turning Up the Heat on California’s 2025 Employment Law Changes

Buchalter on

As the new year approaches, several critical legislative changes in employment law will take effect on January 1, 2025, unless specified otherwise. California employers face a dynamic regulatory landscape in 2025, with...more

Pillsbury Winthrop Shaw Pittman LLP

From AI Doomers to E/Accs: How SB 1047 and the 38 AI Laws in California Are Shaping Future AI Law

California’s Safe and Secure Innovation for Frontier Artificial Intelligence Models Act is one of the first significant regulations of artificial intelligence in the United States that, if signed, would place liability on the...more

Holland & Hart LLP

New Mexico Stiffens Penalties for Air Quality Violations and Tightens Environmental Audit Policy

Holland & Hart LLP on

On September 4, 2024, the New Mexico Environment Department’s Air Quality Bureau (AQB) updated its Civil Penalty Policy, making several key changes to its assessment of civil penalties and administrative compliance costs in...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

DOL’s Child Labor Enforcement Expected to Be Hotter Than Ever This Summer

In fiscal year (FY) 2023, more than half of all U.S. Department of Labor (DOL) child labor investigations resulted in a violation. Of the 955 child labor investigations with violations—a 14 percent increase over the prior...more

Gardner Law

CMS Audits on the Horizon: Prepare for Increased CMS Audits Under the Sunshine Act

Gardner Law on

Historically, the Centers for Medicare and Medicaid Services (“CMS”) has not aggressively pursued enforcement activity under the Sunshine Act. However, this may change in 2024. Late last year, CMS updated its Open Payments...more

Akin Gump Strauss Hauer & Feld LLP

2024 Guide to DOJ and HHS OIG Guidance on Effective Compliance Programs

The Department of Health & Human Services’ Office of Inspector General (HHS OIG) and U.S. Department of Justice (DOJ) have published important guidance and recommendations for pharmaceutical companies to develop and implement...more

Cornerstone Research

PCAOB Enforcement Activity in 2023 Reached its Highest Level Since 2017 as Monetary Penalties Nearly Doubled Previous Record

Cornerstone Research on

The Public Company Accounting Oversight Board (PCAOB) expanded its enforcement activity to the highest level since 2017, according to a new report released today by Cornerstone Research. Monetary penalties imposed by the...more

King & Spalding

PCAOB Division of Enforcement’s First Quarter Continues Record-Setting Pace

King & Spalding on

The PCAOB’s Division of Enforcement and Investigations’ 2024 first quarter activity continued the blistering pace of enforcement since Erica Williams became the Board’s Chair. While the Board’s first quarter enforcement...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: March 1, 2024

The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more

Venable LLP

New York Attorney General Says JBS Net Zero Claims Are Greenwashing

Venable LLP on

Last week, New York Attorney General Letitia James filed a lawsuit against the world’s largest beef producer JBS USA Food Company and JBS USA Food Company Holdings (JBS Group). The lawsuit challenges the company’s claim that...more

Gardner Law

CMS Auditing Companies for Sunshine Compliance: Are You Ready?

Gardner Law on

As the Sunshine Act reporting deadline of March 31, 2024 draws near, medical device and pharmaceutical companies are gearing up for their Sunshine Act reporting. Are you prepared for a Sunshine Act audit? Reporting...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

Seward & Kissel LLP on

The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

Pierce Atwood LLP

FERC Releases Fiscal Year 2023 Annual Enforcement Report

Pierce Atwood LLP on

The Federal Energy Regulatory Commission’s (FERC) Office of Enforcement (OE) recently issued its Fiscal Year 2023 Annual Report on Enforcement. As in previous years, the Enforcement Report discusses the activities performed...more

Mitchell, Williams, Selig, Gates & Woodyard,...

112(r)/Air Enforcement: U.S. Environmental Protection Agency and Cranston, Rhode Island, Beverage Manufacturing/Bottling Facility...

The United States Environmental Protection Agency (“EPA”) and Bottling Group, LLC, operating as Pepsi Beverages Company, and CB Manufacturing Company, Inc., (collectively, “Pepsi”) entered into a September 25th Consent...more

Foley & Lardner LLP

HHS OIG: New “General Compliance Program Guidance” Provides Voluntary Steps Towards Increased Effectiveness

Foley & Lardner LLP on

In connection with the November 2023 Health Care Compliance Association’s (HCCA) Healthcare Enforcement Compliance Conference, and with acknowledgment by the Chief Counsel to the Inspector General, Rob DeConti, of the long...more

King & Spalding

CMS Publishes Final Rule Regarding CMPs for Late Reporting by Medicare Secondary Payers

King & Spalding on

On October 11, 2023, CMS published a final rule (the Final Rule) regarding how and when CMS will impose civil monetary penalties (CMPs) for Medicare secondary payers (MSPs) that untimely report required information. The Final...more

Hudson Cook, LLP

Are Your Employees Taking Loan Applications? The Reach and Consequence of Mortgage Loan Originator Licenses

Hudson Cook, LLP on

One of the more nuanced licensing issues that can arise under state credit laws is the need for individual mortgage loan originators (MLOs) to be licensed. On its face, the MLO license seems relatively straightforward....more

Holland & Knight LLP

Smackdown in SPAC Town: SEC Penalizes Pair of Auditors and PCAOB Tags In

Holland & Knight LLP on

The SEC did not take time off for the summer when it comes to enforcement activity involving auditors of special purpose acquisition companies (known as SPACs and addressed by us previously). While others may have been...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Class V Wells/Safe Drinking Water Act: U.S. Environmental Protection Agency and Hawaiian Convenience Store Operator Enter into...

The United States Environmental Protection Agency (“EPA”) and Seven-Eleven Hawaii, Inc. (“Seven-Eleven”) entered into an August 10th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Underground...more

King & Spalding

OIG Publishes the Spring 2023 Semiannual Report to Congress

King & Spalding on

OIG released its Semiannual Report to Congress (the Report) which summarizes the agency’s activities from October 1, 2022, through March 31, 2023 (the Reporting Period). Among other accomplishments, the Report highlights...more

Davis Wright Tremaine LLP

EEOC Reminds Employers That Automated Decision-Making Systems Might Discriminate

Guidance explains the "four-fifths rule" to determine whether tools for hiring and promotion might result in a disparate/adverse impact on a protected class - Last week, the Equal Employment Opportunity Commission (EEOC)...more

ArentFox Schiff

Key Takeaways from OCR’s Latest Annual HIPAA Reports to Congress

ArentFox Schiff on

On February 17, 2023, the US Department of Health and Human Services Office for Civil Rights (OCR) released two companion reports to Congress detailing its actions in 2021 to enforce the privacy, security, and breach...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: October 1, 2022

The Nutter Securities Enforcement Update is a periodic summary of noteworthy recent securities enforcement activity, settlements, decisions, and charges. ...more

Health Care Compliance Association (HCCA)

Report on Medicare Compliance Volume 30, Number 28. News Briefs: August 2021

Report on Medicare Compliance 30, no. 28 (August 2, 2021) - CMS has not fined any hospitals yet for noncompliance with price transparency requirements, a spokesperson tells RMC. “In April 2021, CMS began issuing warning...more

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