Hospitals continue to be under the Department of Justice-HHS/Office of Inspector General microscope. DOJ-OIG is a potent combination and carry with them the threat of criminal prosecution, civil false claims enforcement and...more
On April 3, 2013, the Department of Justice (DOJ) and Intermountain Health Care, Inc. (Intermountain) entered into a settlement agreement resolving Intermountain’s potential liability under the Stark Law and False Claims Act....more
Federal enforcement of False Claims Act (FCA), Stark anti-kickback, and HIPAA/HITECH claims against healthcare companies continues to rise rapidly. FCA recoveries by the U.S. Department of Justice (DOJ) exceeded $9.5 billion...more
It is always important to consider how different parts of the government handle voluntary disclosures. The FCPA enforcement initiative has been largely the result of the voluntary disclosure process, and the government...more
From the perspective of False Claims Act (FCA) results, 2012 was a decidedly mixed year for healthcare providers. The bad news was quite bad—increased FCA scrutiny by the Department of Justice (DOJ) led to $3 billion of...more
Healthcare providers, particularly physicians and hospitals, regularly engage in business arrangements that may implicate the federal self-referral law, known as the Stark Law. Recent changes to the Stark Law, including...more
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