Drawing on a carrot and stick approach, Department of Justice (“DOJ” or the “Department”) guidance in 2023 focused heavily on incentivizing companies to voluntarily self-disclose their misconduct. This guidance included the...more
4/25/2024
/ Compliance ,
Cooperation ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
FEPA ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
Healthcare Fraud ,
Incentives ,
Pilot Programs ,
Safe Harbors ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Awards ,
White Collar Crimes
On February 24, 2021, DOJ’s Criminal Division Fraud Section published its annual year-end summary. The Fraud Section focuses on prosecuting white-collar crime. The report summarizes enforcement activity in the past year and...more
3/9/2021
/ Big Data ,
Bribery ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Health Care Providers ,
Healthcare Fraud ,
Kickbacks ,
Opioid ,
Prescription Drugs ,
Telemedicine
As discussed in our article recently published by Law360, criminal health care enforcement in 2019 was in many ways a continuation of 2018, with opioid-related enforcement continuing to be the clear top priority for the...more
1/23/2020
/ Bribery ,
Controlled Substances Act ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Guilty Pleas ,
Health Care Providers ,
Healthcare Fraud ,
Kickbacks ,
Medical Devices ,
Medical Necessity ,
Medicare Beneficiaries ,
OIG ,
Opioid ,
Physicians ,
Prescription Drugs ,
Telemedicine
Criminal healthcare enforcement in 2018 once again focused heavily on opioids, targeting manufacturers, prescribers, dispensers and those who contribute to the addiction epidemic, and on prosecution of individuals for a...more
1/10/2019
/ Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Health Care Providers ,
Healthcare ,
Healthcare Fraud ,
Medical Devices ,
Off-Label Promotion ,
RICO ,
White Collar Crimes ,
Yates Memorandum
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
Like many before it, this year has been one to watch in government health care fraud enforcement efforts. In September 2015, the Department of Justice (DOJ) released the “Yates Memo,” which reaffirmed the government’s...more
6/28/2016
/ Acquittals ,
Affirmative Defenses ,
Anti-Kickback Statute ,
Corporate Counsel ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Good Faith ,
Healthcare Fraud ,
Jury Instructions ,
Kickbacks ,
Pharmaceutical Industry ,
Popular ,
Yates Memorandum