News & Analysis as of

False Claims Act (FCA) › Permissive Exclusion Authority

Proskauer - Health Care Law Brief

Another Unique Integrity Agreement Signals a Trend towards HHS-OIG’s Comfort with a Belt and Suspenders

Proskauer - Health Care Law Brief on

In recent years, there have been only a handful of corporate integrity agreements (“CIAs”) and integrity agreements (“IAs”) that have included a “conditional exclusion release” of the Office of the Inspector General for the...more

Sheppard Mullin Richter & Hampton LLP

New OIG Exclusion Authority Rule Set To Go Into Effect on March 21, 2017

Sheppard Mullin Richter & Hampton LLP on

On January 12, 2017, just a week prior to President Trump’s Inauguration, the Department of Health and Human Service (HHS) Office of Inspector General (OIG) published a final Rule (Rule) regarding one of its most important...more

McDermott Will & Emery

New OIG Exclusion Regulations About to Go into Effect

McDermott Will & Emery on

The Office of Inspector General (OIG) recently published a final rule regarding its exclusion authorities. The final rule goes into effect March 21, 2017, and expands OIG’s authority to exclude certain individuals and...more

Baker Donelson

OIG Updates Permissive Exclusion Criteria – Suggests Compliance Programs Are Expected

Baker Donelson on

On April 18th, the Office of Inspector General (OIG) issued updated guidance describing the factors it will consider in determining whether to exercise its permissive authority to exclude individuals and entities from federal...more

Saul Ewing LLP

U.S. Department of Health and Human Services Updates Criteria for Permissive Exclusion Under Section 1128(b)(7) of the Social...

Saul Ewing LLP on

The HHS-OIG issued new guidelines on April 18, 2016 regarding the Secretary's exercise of the Department's permissive exclusion authority pursuant to Section 1128(b)(7) of the Social Security Act. The HHS-OIG's new guidance...more

Arnall Golden Gregory LLP

OIG Releases Revised Policy Statement on Exclusion Authority

Arnall Golden Gregory LLP on

On April 18, 2016, the Office of Inspector General of the Department of Health and Human Services (OIG) released a revised policy statement on its exclusion authority, entitled Criteria for Implementing Section 1128(b)(7)...more

McDermott Will & Emery

OIG Issues New Exclusion and CIA Guidance

McDermott Will & Emery on

On April 18, 2016, Inspector General Daniel R. Levinson announced the publication of updated guidance on how the Office of Inspector General (OIG) makes decisions about using its permissive exclusion authority and requiring...more

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