Last year was another busy year in health care fraud enforcement. In 2012, the Office of Inspector General for the Department of Health and Human Services (HHS-OIG) reported total expected recoveries of $6.9 billion from all of its enforcement initiatives. Additionally, HHS-OIG excluded 3,131 individuals and entities from participation in federal health care programs; brought criminal actions against 778 individuals and entities alleged to have engaged in crimes against HHS programs; and filed 367 civil actions — including federal False Claims Act (FCA ) suits, federal actions under the Civil Monetary Penalties Law, and other administrative proceedings. Also, 2012 saw the single largest takedown (in terms of the amount of Medicare false billings at stake) in the history of the Medicare Fraud Strike Force. Two hundred HHS-OIG special agents, forensic examiners, and analysts executed a takedown across seven cities of over 100 individuals involved in Medicare fraud schemes linked to $452 million in total Medicare false claims.

The enforcement numbers speak for themselves and reinforce a message that has become increasingly clear over the past few years: the federal government’s commitment to health care fraud enforcement remains steadfast, and its investment in such efforts is still paying dividends. This report will review some of the enforcement trends that continued from 2011 into 2012 and highlight the areas in which we expect to see intensified enforcement efforts in the coming year.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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