News & Analysis as of

Qui Tam Self-Disclosure Requirements

Health Care Compliance Association (HCCA)

Private-pay “crime stoppers”: Digesting the Corporate Whistleblower Awards Pilot Program

The U.S. Department of Justice’s (DOJ) Criminal Division launched its Corporate Whistleblower Awards Pilot Program (“Criminal Whistleblower Program”) in August of 2024 to encourage tips for various types of fraud, including...more

Whiteford

Preparing For 2025 Stark Enforcement Regarding Compensation and Productivity Bonuses

Whiteford on

In 2024, Stark enforcement remains a critical focus for healthcare providers and regulatory bodies, with a continued focus on excessive compensation and productivity bonuses. Compliance with Stark Law is essential to avoid...more

Gardner Law

DOJ Enforcement Insights: Key Strategies to Mitigate Risks

Gardner Law on

The DOJ had a record year, and we reviewed FCA enforcement action trends to identify trends to help you stay informed and proactive in your compliance efforts. This alert summarizes key takeaways from Amanda Johnston’s recent...more

Bracewell LLP

The Race to Report: DOJ Announces Pilot Whistleblower Program

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In recent years, the Department of Justice (DOJ) has rolled out a significant and increasing number of carrots and sticks aimed at deterring and punishing white collar crime. Speaking at the American Bar Association White...more

Snell & Wilmer

DOJ Incentivizes Voluntary Self-Disclosure of Corporate Criminal Misconduct in Policy Directive to U.S. Attorneys’ Offices...

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On February 22, 2023, the Department of Justice (“DOJ”) announced that all 93 United States Attorneys’ Offices throughout the country are implementing, effective immediately, a Voluntary Self-Disclosure Policy (“Policy”) for...more

Bass, Berry & Sims PLC

False Claims Act Fundamentals: Self-Disclosures

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When healthcare providers and other government contractors are subject to scrutiny for bills submitted to the government, it is often the result of a whistleblower complaint filed under the qui tam provisions of the False...more

Mintz - Health Care Viewpoints

Pharmaceutical Manufacturer Pays $7.9 Million to Resolve Allegations that it Caused the Submission of Over-the-Counter Drugs to...

On September 15, 2022, the Department of Justice (DOJ) announced a $7.9 million settlement with generic manufacturer Akorn Operating Company LLC (Akorn) to resolve allegations that Akorn caused the submission of...more

Perkins Coie

Getting Cooperation Credit Under New DOJ False Claims Act Guidance

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The U.S. Department of Justice (DOJ) released long awaited guidance last week on how it will evaluate and credit self-disclosures and cooperation in False Claims Act (FCA) cases. The new guidelines, codified in the DOJ’s...more

Holland & Knight LLP

Cooperation Credit in False Claims Act Cases

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Companies facing liability under the False Claims Act (FCA) often desire early resolution with the Department of Justice (DOJ) through settlement. Hand in hand with the decision to settle comes the decision of whether or not...more

Holland & Knight LLP

Self-Disclosure and the FCA Statute of Limitations

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Most practitioners are aware that the statute of limitations under the False Claims Act (FCA) is six years after the date on which the violation is committed. 31 U.S.C. § 3731(b)(1). That is, unless the FCA’s tolling...more

Morrison & Foerster LLP

KBR And Maintaining Privilege Throughout Investigations

Last month, for the second time, the D.C. Circuit in In re Kellogg Brown & Root Inc., No. 14-5319, slip op. (D.C. Cir. Aug. 11, 2015), granted a writ of mandamus sought by KBR and vacated a series of district court orders...more

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