Corporate Integrity Agreement

News & Analysis as of

Final Curtain Call for Tuomey: Long-Running FCA/Stark Case Settled

After 10 years of litigation, including two trials and appeals to the 4th Circuit Court of Appeals, the U.S. Department of Justice (DOJ) and Tuomey Healthcare System (Tuomey) have entered into a settlement of DOJ's action...more

Millennium Health to Pay $256 million in False Claims Act Settlement

Millennium Health, one of the nation’s largest urine drug testing laboratories, has agreed to pay the government $256 million to resolve claims that it violated the Federal False Claims Act (“FCA”). The Settlement...more

Millennium Health and DOJ Settle False Claims Act Allegations for $256 Million

On October 19, 2015, the Department of Justice (DOJ), through the United States Attorney’s Office for the District of Massachusetts, announced that Millennium Health (formerly Millennium Laboratories) had agreed to resolve...more

Tuomey Resolves Stark Law and False Claims Act Judgment for $72.4 Million

The Department of Justice announced on October 16, 2015 a settlement agreement with Tuomey Healthcare System that resolves a $237 million judgment against the system involving claims submitted to the Medicare program in...more

Toumey Healthcare Settles False Claims Act Suit for $72 Million

In a long-running False Claims Act case with significant implications for hospitals, Toumey Healthcare System last week agreed to settle its case by paying $72.4 million to the government. While this sum is significant, it is...more

Mintz Levin Health Care Qui Tam Update: Recently Unsealed Whistleblower Cases: October 2015

Trends & Analysis: ..We have identified 15 health care–related qui tam cases that were unsealed since our last Qui Tam Update. Of those, 12 were filed from 2012 to the present. All but two cases had been pending more...more

Huge Stark Law Hospital Settlements and Physician Culpability - The New Normal Post-Tuomey?

After the federal government’s victory against Tuomey Hospital, we have seen an increasing number of large False Claims Act (FCA) settlements with hospitals involving Stark Law allegations. Relators are even citing, as...more

Health Update - September 2015

Latest Healthcare False Claims Act Roundup and Top 3 Best Practices to Reduce Exposure - As the legal landscape in healthcare becomes increasingly complex, healthcare companies that receive federal program funds face...more

Highway 61 Revisited-Tombstone Blues and Corporate Integrity Agreements

I conclude my tribute to my favorite Bob Dylan album, Highway 61 Revisited with a look at the most surreal song on the disc, Tombstone Blues. I want to use it to contrast the most excellent article that appears today as a...more

Florida Nursing Home Pays Record Settlement to Resolve Federal Anti-Kickback Case

In a recent case Hebrew Homes Health Network, Inc. and its former president and executive Director agreed to pay $17 million to settle allegations that Hebrew Homes violated the federal anti-kickback statute. According to the...more

July FCPA Compliance Digest | Bonus: Global Anti-Corruption News

July was a quiet month for FCPA compliance news. There were some rumors that the SEC and DOJ were in the process of revising A Resource Guide to the US Foreign Corrupt Practices Act, but unfortunately The FCPA Blog shut down...more

Court Concludes that Violation of a Corporate Integrity Agreement May Form the Basis for Reverse False Claim Liability

In late July, a federal district court in Pennsylvania denied a motion to dismiss brought by pharmaceutical company Cephalon, Inc., concluding that violations of a corporate integrity agreement (“CIA”) entered into by...more

Blog: Court Holds Corporate Integrity Agreement May Be Basis for Reverse False Claim Liability

This week, a federal district court denied Cephalon Inc.’s (Cephalon) motion to dismiss a third amended complaint filed under the False Claims Act (FCA) by three qui tam relators in United States ex rel. Boise v. Cephalon,...more

HHS OIG Creates New Taskforce to Pursue Civil Monetary Penalties and Exclusions

At the annual meeting of the American Health Lawyers Association (AHLA) held this week in Washington D.C., the U.S. Department of Health and Human Services Office of Inspector General (OIG) announced a new legal team...more

Record $17M Settlement Of False Claims Act Lawsuit Alleging Doctor Kickbacks

Hailed as “another achievement” for the government’s Health Care Fraud Prevention and Enforcement Action Team (referred to as “HEAT”), the U.S. Department of Justice has announced that a Florida skilled nursing company and...more

Real Guidance (Finally) On the Compliance Oversight Role of Boards

New guidance for boards of directors on what it means to have “reasonable oversight” for the implementation and effectiveness of corporate compliance programs could signal the beginning of a global trend towards more—and more...more

Miami Nursing Home To Pay Record $17M in Whistleblower Suit

A Miami-based nursing home network agreed Tuesday to pay a record $17 million to settle a False Claims Act suit brought by its former CFO, accusing it of running a kickback scheme. The case is United States of America et al...more

Watch Out! Recent Government Settlements Implicate Referring Physicians and Laboratories

$48.5 million settlement with Health Diagnostics Laboratory, Inc. and Singulex, Inc. - On April 9, 2015, the U.S. Department of Justice ("DOJ") announced a $48.5 million settlement with two cardiovascular diagnostic...more

"HHS OIG Issues New Compliance Oversight Guidance for Boards of Directors"

On April 20, 2015, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) published its “Practical Guidance for Health Care Governing Boards on Compliance Oversight” (the Guidance).1...more

Two Laboratories Settle Claims Regarding Specimen Processing Fees

Continuing the scrutiny of laboratory arrangements with referring physician practices, the United States Department of Justice (DOJ) recently announced the settlement of False Claims Act allegations against two cardiovascular...more

Spotlight on Responsibility and Accountability: OIG’s New Compliance Guidance for Health Care Governing Boards

On April 20, 2015, the Office of the Inspector General of the U.S. Department of Health and Human Resources (“OIG”), in collaboration with the American Health Lawyers Association, the Association of Healthcare Internal...more

Catching Up on the False Claims Act

From a corporate risk perspective, if your company is in the financial industry, healthcare, or defense industry, your greatest legal and compliance risk has to be the False Claims Act....more

2015 Trends: #7 Crime and Punishment

On the accountability and punishment front, three trends bear watching: 1) Deferred Prosecution Agreements (DPAs) DPAs and Non-Prosecution Agreements (NPAs) allow prosecutors to require corporate reforms and...more

Buy High, Sell Low, and Restrict Competition: The Allegations Underlying the Government’s Case Against DaVita and the Implications...

On October 22, DaVita HealthCare Partners Inc., one of the nation’s largest dialysis companies, and its wholly owned subsidiary, Total Renal Care, Inc. (collectively, “DaVita”), agreed to pay $389 Million to settle...more

How to Protect Attorney-client Privilege in Internal Investigations

While attorney-client privilege can protect many internal documents, recent court decisions highlight the need to explicitly invoke this protection. As many US policies now require an increased level of internal...more

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