In 2018, the False Claims Act (“FCA”) continued to be one of the federal government’s (“Government”) preferred civil fraud enforcement tools across a variety of industries. The healthcare industry, however, remained the...more
In Part 3 of our series on health care investigations, Mark Rush and John Lawrence discuss the process for external investigations conducted by federal and state governmental agencies, including in the context of qui tam...more
11/27/2018
/ Civil Investigation Demand ,
Dismissals ,
Employee Rights ,
False Claims Act (FCA) ,
Frivolous Lawsuits ,
Government Agencies ,
Government Investigations ,
Health Care Providers ,
Healthcare Fraud ,
Internal Investigations ,
Obstruction of Justice ,
Qui Tam ,
Search & Seizure ,
Search Warrant ,
Subpoenas ,
Whistleblowers
In Part 2 of our series on health care investigations, Mark Rush and John Lawrence continue the discussion on internal investigations. Specifically, the episode walks through how to conduct an internal investigation,...more
11/27/2018
/ Audits ,
Bias ,
Corrective Actions ,
Data Collection ,
Disclosure Requirements ,
Document Destruction ,
Health Care Providers ,
Healthcare Facilities ,
Healthcare Fraud ,
Healthcare Workers ,
Internal Investigations ,
Interviews ,
Outside Counsel ,
Policies and Procedures ,
Reporting Requirements ,
Self-Disclosure Requirements ,
Upjohn Warnings
On October 24, 2018, President Trump signed into law comprehensive opioid legislation known as the “Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act” or the...more
In this episode, Mark Rush and John Lawrence discuss the federal government’s expectations related to health care organizations conducting internal investigations and demonstrating a commitment to compliance. The episode also...more
10/30/2018
/ Anti-Kickback Statute ,
Civil Liability ,
Civil Monetary Penalty ,
Criminal Prosecution ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Government Investigations ,
Health Care Providers ,
Healthcare Fraud ,
Hospitals ,
Internal Investigations ,
OIG ,
Qui Tam ,
Risk Mitigation ,
Stark Law
On July 27, 2018, the Medicare Physician Fee Schedule (PFS) Proposed Rule for Calendar Year (CY) 2019 (PFS Proposed Rule) was published in the Federal Register....more
8/8/2018
/ Centers for Medicare & Medicaid Services (CMS) ,
Comment Period ,
Drug Pricing ,
Health Care Providers ,
Medicare ,
Off-Campus Departments ,
Outpatient Prospective Payment System (OPPS) ,
Physician Fee Schedule ,
Physicians ,
Proposed Rules ,
Section 340B
Recently, the U.S. Department of Justice (DOJ) and Department of Health and Human Services (HHS) announced its largest ever national health care fraud takedown, resulting in charges against 601 diverse defendants including...more
7/19/2018
/ Anti-Fraud Provisions ,
Anti-Kickback Statute ,
Bribery ,
Corruption ,
Criminal Conspiracy ,
Criminal Prosecution ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Drug Distribution ,
Enforcement Actions ,
False Billing ,
False Claims Act (FCA) ,
FBI ,
Health Care Providers ,
Healthcare Fraud ,
Medicaid ,
Medicare ,
Medicare Fraud Strike Force ,
OIG ,
Opioid ,
Pharmaceutical Industry ,
Pharmacies ,
Physicians ,
Prescription Drugs ,
State Attorneys General ,
TRICARE