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
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
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
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
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
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
8/6/2020
/ Compliance ,
Coronavirus/COVID-19 ,
Corporate Misconduct ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Health Care Providers ,
Healthcare Fraud ,
Qui Tam ,
Relators ,
Risk Mitigation
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
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
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
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
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
1/3/2020
/ Crime Victims ,
Hospitality Industry ,
New Legislation ,
Nonprofits ,
Public Entities ,
Public Policy ,
Regulatory Reform ,
Sexual Abuse ,
Sexual Assault ,
State and Local Government ,
Statute of Limitations ,
Vulnerable Victims
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
11/5/2019
/ Affiliates ,
Bad Actors ,
Centers for Medicare & Medicaid Services (CMS) ,
Children's Health Insurance Program (CHIP) ,
Durable Medical Equipment ,
Enrollment ,
Health Care Providers ,
Healthcare Fraud ,
Healthcare Reform ,
Medicaid ,
Medicare ,
Revocation ,
Suppliers
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
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
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