On January 10, 2025, OIG posted a favorable advisory opinion approving a proposed program (Program) to provide patients who meet certain financial need criteria with free access to a pharmaceutical product that has limited...more
The HHS Office of Inspector General (OIG), in connection with its enforcement responsibilities, must exclude a party from the federal health care programs if the party is found to have violated certain federal laws. This type...more
UCHealth Settles FCA Violations for $23 Million - On November 12, the US Department of Justice (DOJ) announced that University of Colorado Health (UCHealth) agreed to resolve allegations that it violated the False Claims...more
Florida Federal Judge Strikes Down FCA’s Qui Tam Provision as Unconstitutional - On September 30, US District Judge Kathryn Kimball Mizelle of the Middle District of Florida held in a historic decision that the federal...more
The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more
Community Health Network, Inc., based in Indianapolis, Indiana, has paid $345 million to settle alleged violations of the False Claims Act (FCA). The lawsuit was initiated through a whistleblower complaint that was filed in...more
The Department of Health and Human Services’ Office of Inspector General (OIG) published a General Compliance Program Guidance (GCPG) on November 6, 2023, marking the first update to OIG’s compliance program guidance...more
Engineering Company Agrees to Pay $4.4 Million to Settle FCA - On Friday, September 15, 2023, the US Department of Justice (DOJ) announced a settlement agreement with Navmar Applied Sciences Corporation, a...more
Recent cases of fraud and abuse in the healthcare industry serve as a reminder of the importance of healthcare law compliance and ethical medical business practices. One such case is the qui tam relator case against...more
It is no surprise that the use of telemedicine as a means of providing patients with access to medical care has increased significantly in recent years. Likewise, the number of telemedicine companies offering a broad range of...more
The United States Supreme Court recently agreed to hear a case interpreting the False Claims Act (“FCA”) that may affect the government’s involvement in pending and future matters. To resolve a circuit split, the Court will...more
Most health care providers recognize that submitting a knowingly false claim to a federally funded health care program violates the False Claims Act (FCA). However, it is less well known that indirectly "causing" someone else...more
• 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
Last fall, CMS published a booklet, “Medicare Fraud & Abuse: Prevention, Detention, and Reporting.” It was prepared by the CMS Office of Inspector General to assist in combatting fraud and abuse in federal health care...more
In OIG Advisory Opinion 18-01, published February 27, 2018, the OIG concluded a proposed employment arrangement between an excluded individual and a for-profit company selling discounted emergency medications to long term...more
Recent congressional action will have serious ramifications on corporate and individual defendants who are or could be under investigation for violations of federal health care program fraud and abuse laws. Changes...more
On July 13, 2017, the Department of Justice ("DOJ"), in conjunction with the Department of Health and Human Services ("HHS"), continued its annual tradition of coordinating the filing of charges and sweeping arrests in...more
Continuing its annual tradition, the U.S. Department of Justice (“DOJ”) and the U.S. Department of Health and Human Services (“HHS”) announced last week the largest ever health care fraud enforcement action by the Medicare...more