Jonathan Rosen

Jonathan Rosen


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Latest Publications


DOJ Hires Compliance Counsel to Aid in Charging Decisions

In today’s robust enforcement climate, most companies have taken at least the first steps towards establishing a formal corporate compliance program. The mere existence of such a program, however, will not by itself protect a...more

8/12/2015 - Compliance Criminal Prosecution DOJ False Claims Act FCPA Fraud Healthcare Healthcare Fraud Securities Fraud

Wisconsin Repeals State False Claims Act

On July 12, 2015, the state of Wisconsin passed a budget that, along with many expected cuts, additions, and tweaks, unexpectedly repealed Wisconsin’s False Claims for Medical Assistance Act—the state’s version of the federal...more

7/24/2015 - False Claims Act Fraud Healthcare Medicaid Qui Tam Whistleblowers

Whistleblower's Criminal Conduct Prevents FCA Payout

The United States Court of Appeals for the Ninth Circuit prevented a False Claims Act (“FCA”) relator from receiving a share of a $19 million settlement stemming from the defendant’s alleged false billing on a nuclear cleanup...more

7/21/2015 - Appeals False Billing False Claims Act Nuclear Waste Qui Tam Relators Whistleblowers

CMS Report Underscores Importance for Providers to Know Their Data

On July 14, 2015, CMS issued a report regarding its implementation of the Fraud Prevention System, which uses predictive analytics to manage government fraud and False Claims Act investigations. According to this report, CMS...more

7/20/2015 - CMS Compliance False Claims Act Fraud Prevention Healthcare Healthcare Providers Medicaid Medicare

Fourth Circuit Upholds $237 Million Stark Judgment

On July 2, 2015, the United States Court of Appeals for the Fourth Circuit affirmed a $237 million judgment against Tuomey Healthcare System, Inc. (“Tuomey”), in a federal False Claims Act (“FCA”) case arising out of...more

7/15/2015 - CMS Employment Contract False Claims Act Healthcare Hospitals Medicare Patient Referrals Physicians Self-Referral Disclosure Protocol Stark Law

What Companies Can Learn From The Ralph Lauren Corporation FCPA Case

Last week, a subsidiary of American fashion designer Ralph Lauren Corporation made global news for violations of The Foreign Corrupt Practices Act of 1977 ("FCPA"). In short, FCPA prohibits covered entities – i.e., those that...more

5/7/2013 - Compliance DOJ FCPA Non-Prosecution Agreements Ralph Lauren SEC

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