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Addressing New Risks: FinCEN Sets Priorities for Combating Money Laundering and Terrorism Financing

On June 30, 2021, the Financial Crimes Enforcement Network (“FinCEN”), issued the first government-wide Priorities for anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) policy (the “Priorities”)....more

A Step Towards Clarity? The NYC Bar Compliance Committee Seeks to Set Forth Guidance on Bringing Enforcement Action Against Chief...

Over the past 15 years, chief compliance officers (“CCOs”) for financial services firms have come under increased scrutiny as the Securities and Exchange Commission (“SEC”) and Financial Industry Regulatory Authority...more

Following on the Child Victim’s Act, Proposed New York State Legislation Seeks to Revive the Statute of Limitations for Survivors...

The trend in New York State to provide relief for expired claims by waiving statutes of limitation in sex-abuse cases may be continuing. As its current session winds down, the New York State Legislature is considering...more

Forecast for Telehealth Fraud and Abuse Risk in 2021 - Diagnosing Health Care Podcast [Video]

This Diagnosing Health Care episode examines the fraud and abuse enforcement landscape in the telehealth space and considers ways telehealth providers can mitigate their enforcement risks as they move into the new year. Hear...more

Opioids, Sober Homes and “Telefraud”: an Overview of the DOJ 2020 Healthcare Fraud Takedown

In September 2020, the U.S. Department of Justice (“DOJ”) and the U.S. Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) announced its annual healthcare-related “takedown.” The takedown,...more

Fraud and Abuse Enforcement Priorities in the Wake of COVID-19 - Diagnosing Health Care Podcast [Video]

In this Diagnosing Health Care episode, hear how the government’s fraud and abuse enforcement priorities have shifted as a result of the COVID-19 pandemic and how compliance programs must also pivot to mitigate new risks. The...more

DOJ Revises Guidance on Corporate Compliance Programs: Evolving Towards More Individualized Evaluations

Companies need to be aware of updated guidelines issued by the U.S. Department of Justice (“DOJ”) – Criminal Division governing how the agency will evaluate corporate compliance programs. Released on June 1, 2020, the...more

OIG Offers an Alternative to Advisory Opinions for Emergency Arrangements During the Public Health Emergency

In an effort to ensure that health care providers have the regulatory flexibility they need to adequately respond to COVID-19 concerns during the current public health emergency, the U.S. Department of Health and Human...more

First Federal COVID-19-Related Enforcement Action Filed as DOJ and FBI Commit to Preventing Fraud in the Nation’s Response to the...

After U.S. Attorney General, William P. Barr and the Federal Bureau of Investigation issued warnings this week regarding potential fraudulent schemes that are being perpetrated in the nation’s response to the COVID-19...more

In an Unprecedented Move, OIG Expands Access to Telehealth in Response to the COVID-19 Outbreak

On March 17, 2020, the U.S. Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) issued a Policy Statement and a companion Telehealth Factsheet[2] notifying health care providers that they will...more

New Jersey’s New Child Victims Act Expands Opportunity for Filing Abuse Claims and Removes Former Immunity for Non-Profit...

On December 1, 2019, New Jersey’s Child Victim’s Act went into effect. This new law opens a two-year “revival” period for individuals to assert civil claims of child abuse and to file claims against institutions and...more

New Program Integrity Rule Expanding Medicare Revocation and Denial Authorities Took Effect Yesterday

Yesterday, a final rule issued by the Centers for Medicare & Medicaid Services (CMS) establishing new enforcement initiatives aimed at removing and excluding previously sanctioned entities from Medicare, Medicaid, and the...more

Healthcare Fraud Prevention Partnership Issues a Review of Clinical Laboratory Services

The Healthcare Fraud Prevention Partnership (“HFPP”) recently published its second white paper, entitled “Examining Clinical Laboratory Services,” which provides a comprehensive overview of practices that raise fraud and...more

D.C. District Court Clarifies Standard for Laboratory Determination of Medical Necessity

This past June, a federal district court in the District of Columbia made headlines when it declined to dismiss an action brought by a qui tam plaintiff (“Relator”) against defendant Boston Heart Diagnostics (“Boston Heart”),...more

Recent DOJ Guidance Highlights Substantial Benefits of Being Proactive About Compliance

The Criminal Fraud Section of the U.S. Department of Justice (DOJ) recently released guidance entitled “Evaluation of Corporate Compliance Programs,” setting forth over 100 questions in 11 categories that the Fraud Section...more

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