The U.S. Department of Justice (DOJ) and other government enforcers announced a number of key settlements in the life sciences industry in October – December 2019. These settlements include:
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| LIFE SCIENCES INDIVIDUALS/ ENTITIES |
SETTLEMENT DATE |
RESOLUTION |
KEY AREAS OF ENFORCEMENT |
| Pharmaceutical company |
Dec. 3, 2019 |
$3 million
Deferred prosecution agreement
Restitution
|
- Criminal antitrust conspiracy
- False Claims Act
|
| Charitable foundation |
Nov. 20, 2019 |
$4 million
Three year integrity agreement
|
- False Claims Act
- Conduit for pharmaceutical company kickbacks
|
| Medical device company
Founder/president/CEO
VP Business Development
|
Nov. 7, 2019 |
$5.99 million |
- False Claims Act
- Kickbacks
- Consulting fees, royalties, intellectual property acquisition fees
|
| Pharmaceutical supplier |
Nov. 7, 2019 |
$22.05 million |
- False Claims Act
- False and inflated AWP
- Consulting agreement kickbacks
- Illegal waiver of copays
|
| Two charitable foundations |
Oct. 25, 2019 |
$4 million
$2 million
Three-year integrity agreements
|
- False Claims Act
- Conduit for pharmaceutical company kickbacks
|
| Genetic testing company
3 principals
|
Oct. 9, 2019 |
$42.6 million
Exclusion
|
- False Claims Act
- Kickbacks
- Medically unnecessary testing
|
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These settlements demonstrate the continued importance for life sciences companies to monitor industry developments and determine ways in which to improve their corporate compliance programs.
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