In this installment of the Healthcare Enforcement Roundup we cover new and longstanding issues impacting the healthcare enforcement landscape. First, we explore the impact of the Coronavirus (COVID-19) on the healthcare industry, and the heightened risk of enforcement actions, whistleblower complaints and litigation that arise in times of crisis. We also address differing falsity standards that have emerged under the False Claims Act (FCA), the Department of Justice’s (DOJ) FCA enforcement priorities – including an overview of the DOJ’s updated guidance on corporate compliance – and new developments on the enforceability of sub-regulatory guidance that should all be watched by hospitals, health systems and other industry stakeholders. Finally, this issue features updates on key healthcare enforcement issues to watch from past Healthcare Enforcement Roundup reports.

PREPARING FOR THE AFTERMATH OF COVID-19: THE INVESTIGATIONS -

In recent months, the federal government has dedicated trillions of dollars to containing and treating the Coronavirus (COVID-19) and stimulating the economy in response to the pandemic. It has also waived many federal health program requirements to grant providers greater flexibility in combatting the virus. During these challenging times, healthcare providers should remember to practice good compliance hygiene to avoid heightened scrutiny and potential allegations of false claims lobbed by governmental actors and whistleblowers...