Weekly Brief: 78% of Law Schools Ignore ABA Rule
Suzanne Folsom & Christopher Burnham on Private Sector Lessons
On April 17, 2013, the Office of the Inspector General (OIG) of the United States Department of Health and Human Services released an updated Provider Self-Disclosure Protocol (SDP). As self-described, OIG updated the SDP to...more
This month our articles focus on the availability of damages in complex ERISA class actions and withdrawal liability actions. Jackie Len first provides Proskauer's perspective on the implications for ERISA litigation arising...more
Increased Regulation of Interactions with Healthcare Professionals - In an effort to increase the transparency of interactions between pharmaceutical companies and health care professionals the new (17th) edition of...more
There are a number of curious features to the Privacy Notice splash page for Canada’s new online tool for making access to information (ATIP) requests....more
The US Departments of Labor, Health and Human Services (HHS), and the Treasury (the “Agencies”) jointly issued yesterday a document entitled “FAQs about the Affordable Care Act Implementation Part XV” (“FAQs”) addressing four...more
In This Issue: - Third Circuit Panel Liberalizes “Protected Activity” Immunity for Employees Claiming Whistleblower Status - Doing Time: A Requirement for White Collar Crime? - Casting a Smaller Net:...more
The Centers for Medicare & Medicaid Services (“CMS”) recently launched the National Physician Payment Transparency Program: OPEN PAYMENTS website, which provides Sunshine Act compliance resources, including Fact Sheets and...more
Large non-listed companies incorporated in the European Economic Area (“EEA”) which operate in the oil, gas and mining sectors will need to annually disclose any payments made to the national, regional or local authority of a...more
Handbooks for Financial Conduct Authority and Prudential Regulation Authority will replace FSA Handbook on 1 April. On 8 March, the UK Financial Services Authority (FSA) published draft handbooksfor the two new...more
March 7 (Bloomberg Law) -- Bloomberg Law's Lee Pacchia runs through the legal news for the week. New testimony at the BP oil spill trial in New Orleans focuses on a key safety test taken shortly before the accident. Also,...more
One of the concepts articulated in the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) Guidance was that every company should assess its own risks for bribery and...more
On February 27, the Council of the EU and the European Parliament announced that they had reached preliminary agreement on the legislative proposals for the CRD IV reforms, including on the key contentious issue of bankers’...more
Almost daily we hear about a new cyber threat or information security breach. Just last week one of the world's largest cloud services providers, Evernote, fell victim to an attack that resulted in a security breach that...more
As part of a continuing series of LEVICK video interviews with thought leaders across multiple disciplines and industry sectors, I recently sat down with noted good governance experts Suzanne Folsom and Christopher Burnham to...more
A number of significant briefs were filed recently with the U.S. Court of Appeals for the D.C. Circuit in support of Section 1504 of the Dodd-Frank Act, which requires oil, gas, and mining issuers to report on their payments...more
On February 4, 2013, the Online Interest-Based Advertising Accountability Program issued a decision that concluded its inquiry into how the online advertising industry's Self-Regulatory Principles for Online Behavioral...more
In last month’s Technology Advisory, I described recent actions of the California Attorney General designed to improve privacy protections for users of mobile applications. This included an agreement the California Attorney...more
On February 1, the FTC announced that it is requiring a social networking application company to pay $800,000 and make certain compliance enhancements to resolve allegations that the firm (i) misled and deceived users by...more
The Federal Trade Commission has emphasized in the past that general privacy protections in the website space apply equally to mobile services, but a new FTC Staff Report released on Friday hones in on some privacy...more
Reports on Physician Ownership and Investment Interests The Sunshine Act requires applicable manufacturers, as well as applicable GPOs, to report to the Secretary, in electronic form, certain information concerning...more
Report Submission and Review Pre-Submission Review is Not Required Applicable manufacturers may voluntarily provide covered recipients the opportunity to review the data prior to submission to CMS, but doing so is not...more
“Payments or Other Transfers of Value” Payments or Other Transfer of Value Must Have a Discernible Economic Value.In the Final Rule, CMS interprets value as the discernible economic value on the open market in the United...more
Public disclosure of payments from pharmaceutical, medical device, biologic, and medical supply manufacturers to physicians and hospitals will begin under a final rule on the Physician Payments Sunshine Act (Sunshine Act)...more
Late afternoon on Friday February 1, 2013, the Centers for Medicare and Medicaid Services ("CMS") published the final rule regarding Transparency Reports and Reporting of Physician Ownership or Investment Interests ("Final...more
On January 23, 2013, Bruce Karpati, Chief of the Asset Management Unit (the “AMU”) of the Enforcement Division of the Securities and Exchange Commission, addressed the Private Equity International Conference in New York. Mr....more
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