News & Analysis as of

OIG Policy Statement Outlines Conditions Under Which Hospitals May Waive Beneficiary Copayments for Outpatient Self-Administered...

The OIG has issued a policy statement clarifying the conditions under which hospitals may discount or waive Medicare beneficiary copayment amounts for self-administered drugs (SADs) received in outpatient settings without...more

CMS/OIG Finalize Fraud Authority Waivers for Accountable Care Organizations (ACOs) under the Medicare Shared Savings Program...

The Centers for Medicare & Medicaid Services (CMS) and the Office of Inspector General (OIG) have finalized a rule designed to “remove legal and regulatory barriers that can impede care coordination in furtherance of the...more

How Canada’s leading the way to compliance with anti-corruption sticks and carrots

“Your criminal actions raise serious questions as to whether you have the requisite personal integrity and business ethics to be a responsible Government contractor.” That’s me. I was debarred from being a U.S....more

MiFID II: The Next Big Challenge - Key Issues for Asset Managers

Background - The Markets in Financial Instruments Directive (“MiFID II”) and the related Regulation (“MiFIR”) is the next big rewrite of EU legislation, due to take effect at the beginning of 2017. Although its greatest...more

There Is A Difference Between "Inducing" Something and "Causing" Something

If you asked me to list my favorite torts, tortious interference with prospective economic advantage would be near the bottom of the list. But that tort was front and center in Judge McGuire's Opinion in KRG New Hill...more

Financial Services Quarterly Report - Third Quarter 2013: French AMF Guidance on Best Practices Regarding Rebates and Inducements...

Pursuant to the market practice in France, distributors – such as investment service providers or financial advisors – are not paid directly by investors but rather receive a rebate or inducements from the issuer of the...more

New Jersey Department of Banking and Insurance Clarifies Restrictions on the Payment of Commissions, Rebates and Other Inducements...

The New Jersey Department of Banking and Insurance ("NJDOBI") issued a Bulletin to title insurance companies and producers and to real estate brokers, broker-salespersons and salespersons advising them of the restrictions on...more

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