From the Editor’s Desk: Compliance Week’s Insights and Reflections from July to August 2025
AI and the False Claims Act
False Claims Act Insights - Bitter Pills: DOJ Targets Pharmacies for FCA Enforcement
Hospice Insights Podcast - Election Inspection: Be Proactive to Avoid Costly Election Statement Denials
The Trend of Threatening Physicians for Personal Gain
Daily Compliance News: June 17, 2025, The JBS Goes Public Edition
False Claims Act Insights - Will Recent Leadership Changes Lead to FCA Enforcement Policy Changes?
Daily Compliance News: June 16, 2025, The Golden Share Edition
Hospice Insights Podcast - Still Number One: Healthcare Fraud Remains Central in DOJ’s White Collar Enforcement Plan
False Claims Act Insights - How Payment Suspensions Can Impact FCA Litigation
Daily Compliance News: May 16, 2025, The Ethics Nightmare Edition
False Claims Act Insights - Trump DOJ Sharpens Its Focus on Healthcare Fraud
How Life Sciences Companies Can Create a Culture of Compliance When Expanding to the U.S. Market
False Claims Act Insights - DOJ’s Reliance on FCA to Pursue Covid-Related Fraud
UPIC Audits
Criminal Health Care Fraud Enforcement: Projections for 2025 and Beyond – Diagnosing Health Care Video Podcast
AGG Talks: Home Health & Hospice Podcast - Episode 10: Anti-Kickback Compliance for Hospice and Skilled Nursing Providers
False Claims Act Insights - Stranger Than Fiction? An FCA April Fools’ Day Episode
The Presumption of Innocence Podcast: Episode 53 - Diagnosis: Innocent – A Doctor’s Journey to Acquittal
False Claims Act Insights - Reality Checks: How to Approach Healthcare Transactions Without Triggering FCA Liability
On January 10, 2025, China’s State Administration for Market Regulation (“SAMR”) put into effect its Compliance Guidelines for Healthcare Companies to Prevent Commercial Bribery Risks (“Compliance Guidelines”)....more
The Department of Justice (DOJ) recently announced that it obtained more than $2.9 billion in False Claims Act (FCA) settlements and judgments in the fiscal year ending Sept. 30, 2024. DOJ reports that matters that...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
On October 7, 2024, the U.S. Supreme Court declined to hear a case concerning the “willfulness” element of the Anti-Kickback Statute (the “AKS”). This decision leaves intact a recent Second Circuit holding, which established...more
August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more
On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more
In March, the Department of Justice (DOJ) announced that a pilot program to incentivize individualized reporting was in development, which we reviewed here. True to its word, the DOJ's "Corporate Whistleblower Awards Pilot...more
Earlier this month, the U.S. Department of Justice (DOJ) announced its Corporate Whistleblower Awards Pilot Program (Program). The Program—which will last for three years—is designed to incentivize, through money awards,...more
On August 1, 2024, Deputy Attorney General Lisa Monaco announced the launch of DOJ’s Corporate Whistleblower Awards Pilot Program (Pilot Program). The Pilot Program, previewed by Monaco in March 2024, provides another avenue...more
On August 1, 2024, the US Department of Justice’s (DOJ’s) Principal Deputy Assistant Attorney General of the Criminal Division, Nicole Argentieri, unveiled the highly anticipated details of DOJ’s Corporate Whistleblower...more
The federal health care Anti-Kickback Statute (Federal AKS) targets bribery and corruption in the health care industry. There are two core provisions of the Federal AKS: one targeting the bribe recipient and one targeting the...more
Last week the Department of Justice (DOJ) issued its annual report of civil fraud recoveries and statistics under the civil False Claims Act (FCA). The Report can be found, and the accompanying DOJ Press Release can be found....more
In the post-COVID era, health care fraud and abuse issues will be aggressively and swiftly enforced by the government. The legal framework and regulations in the health care space can be intimidating. Below is a comparison of...more
The Department of Justice and the US Attorney offices around the country are continuing to be in hot pursuit of cases of fraud related to the COVID-19 pandemic. On April 20, 2022, the Department of Justice announced a new...more
Last Monday, the Eleventh Circuit ruled that the Middle District of Florida’s sentence of probation for former physician Nicole Bramwell in a $4.4 million Tricare fraud case was substantively unreasonable. The district...more
False Claims Act prosecutions continue against healthcare executives, physicians and professionals. Last year, DOJ recovered over $5.6 billion in FCA enforcement. DOJ expects total recoveries to increase in 2022. Over 95...more
The US Department of Justice’s Criminal Division Fraud Section released its annual Year in Review report on February 15, covering 2021. Despite ongoing aftershocks associated with the global pandemic, this year’s report...more
As for the Judiciary, the U.S. Supreme Court did not issue any relevant decisions nor grant certiorari in any notable FCA cases in FY21. To the contrary, they denied petitions to review appellate cases of potential...more
Worth the Wait? DOJ finally released its Fraud Statistics for FY 2021 and announced the “second largest amount recorded” since 1986: FCPA Settlement and judgment exceed $5.6 billion...more
Last July, Sen. Chuck Grassley (R-IA) spearheaded a bipartisan effort to update the government’s most effective tool for combating fraud, the False Claims Act (“FCA”). Prompted by an uptick of fraudulent activity perpetrated...more
In 2015, then-Deputy Attorney General Sally Yates issued a memorandum to the attorneys of the Justice Department articulating departmental policy on corporate misconduct. This memo became popularly known as the Yates Memo. It...more
Last week, in light of the Department of Justice’s newly-formed COVID-19 Fraud Enforcement Task Force, we cautioned that COVID-related prosecutions were likely imminent. And on the heels of this DOJ task force, we are already...more
If the Biden administration's early moves are any indicator, its Department of Justice (DOJ) is poised to devote more time and energy to the prosecution of white-collar crime than it did under the Trump administration, when...more
The False Claims Act is a powerful tool for government prosecutors to use against healthcare providers, and drug and device companies. The Trump Administration used the False Claims Act to attack the opioid industry and rein...more
Medical device maker Merit Medical Systems (“MMS”) agreed to pay $18 million to resolve allegations that the company submitted false claims to Medicare, Medicaid and TRICARE by paying kickbacks to physicians and hospitals to...more