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DC Circuit Strongly Reaffirms the Applicability of the Attorney-Client Privilege to Internal Compliance Investigations

Especially in the District of Columbia Circuit, the home base for many fraud cases in which the government is opposed to health care providers and defense contractors, there had been considerable doubt that the...more

7/2/2014 - Attorney-Client Privilege Compliance False Claims Act Internal Investigations Kellogg Brown & Root Work-Product Doctrine

Supreme Court Declines to Opine on Circuit Split Over Rule 9(b) Pleading Requirements for FCA Claims

On March 31, 2014, in U.S. ex rel. Nathan v. Takeda Pharmaceuticals North America, the Supreme Court of the United States declined to review a decision by the U.S. Court of Appeals for the Fourth Circuit upholding a district...more

6/7/2014 - Certiorari Dismissals False Claims Act Healthcare Fraud Medicare Off-Label Use Pharmaceutical Pleading Standards Popular Qui Tam Rule 9(b) SCOTUS Split of Authority Takeda Pharmaceuticals Whistleblowers

New Proposed Rules Significantly Expand OIG's Exclusion Power

On May 9, 2014, the Office of Inspector General ("OIG") of the Department of Health and Human Services published in the Federal Register a proposed rule amending the regulations relating to OIG's exclusion authority...more

5/16/2014 - Affordable Care Act Civil Monetary Penalty Exclusions Healthcare HHS Medicare OIG Prescription Drugs

OIG's Special Advisory Bulletin on the Effect of Exclusion—Continuing the Focus on Individual Accountability

On May 8, 2013, the U.S. Department of Health and Human Services' Office of Inspector General ("OIG") released an Updated Special Advisory Bulletin on the Effect of Exclusion from the Participation in Federal Health Care...more

5/23/2013 - Civil Monetary Penalty Exclusions Healthcare OIG Self-Disclosure Requirements

OIG Unveils Updated Self-Disclosure Protocol

In 1998, the Department of Health and Human Services' Office of Inspector General ("OIG") published the Self-Disclosure Protocol ("SDP"), which provides a mechanism through which health care providers may voluntarily report...more

4/23/2013 - Anti-Kickback Statute Civil Monetary Penalty Disclosure Requirements Eligibility OIG Self-Disclosure Requirements Stark Law

HEALTH REFORM: OIG Issues Updated Guidelines for Evaluating State False Claims Acts: Is More State Litigation on the Horizon?

On March 15, 2013, the U.S. Department of Health and Human Services’ Office of Inspector General (“OIG”) released the Updated OIG Guidelines for Evaluating State False Claims Acts (“2013 Guidelines”), which replaces the...more

4/1/2013 - Affordable Care Act Civil Monetary Penalty False Claims Act FERA Healthcare Medicaid OIG Qui Tam

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