News & Analysis as of

Healthcare Corporate Integrity Agreement

Mintz - Health Care Viewpoints

Violations for Excessive Physician Compensation

The Department of Justice (DOJ) recently filed a complaint against Erlanger Health System (Erlanger), a county-owned public health system, and two of its Tennessee hospitals alleging that the health system systemically...more

Foley & Lardner LLP

Compliance Compass: The Erlanger Complaint – A Cautionary Reminder About the Importance of FMV

Foley & Lardner LLP on

Although most health care lawyers and compliance officers who review and analyze physician compensation understand that fair market value (FMV) is important, the nuances around FMV are sometimes missed....more

The Volkov Law Group

HHS-OIG Issues Comprehensive Compliance Guidance that Underscores the Need for a Robust and Independent Compliance Function (Part...

The Volkov Law Group on

The health care industry has a rich history of commitment and innovation in developing effective compliance  programs.  Going back to the 1990s, HHS elevated compliance program requirements for healthcare companies. Many of...more

The Volkov Law Group

Two Charitable Foundations Pay $6 Million for Anti-Kickback Violations

The Volkov Law Group on

Two charitable foundations that helped patients pay for drug co-payments settled anti-kickback charges for $6 million.  The Patient Access Network Foundation (PANF) agreed to pay $4 million and Good Days agreed to pay $2...more

Mintz - Health Care Viewpoints

Insys Bankruptcy Filing Immediately After Global Settlement Triggers Powerful Remedies

Over the last two years, much of the healthcare world has been watching the government’s prosecution of Insys Therapeutics for its sales and marketing practices related to its Subsys spray. Subsys is powerful and highly...more

Jones Day

Public Branding, the OIG's New Method of Punishing Health Care Entities?

Jones Day on

The Situation: The total number of Corporate Integrity Agreements ("CIAs") between the Office of Inspector General ("OIG") and health care entities has been decreasing, and the OIG recently decided it would spotlight entities...more

The Volkov Law Group

Health Management Associates Pays Over $260 Million in Criminal and Civil Penalties for Pervasive False Billing and Kickback...

The Volkov Law Group on

Healthcare Management Associates (HMA) settled criminal and civil charges with the Justice Department for illegal fraud and kickback schemes. HMA billed federal government healthcare programs for inpatient services that...more

The Volkov Law Group

Tenet Healthcare Settles Fraud Case for $514 Million

The Volkov Law Group on

If you work in compliance in the healthcare industry, you have a tough job. The number and variety of risks that healthcare providers face is daunting. The False Claims Act is a mighty weapon in the hands of federal...more

McDermott Will & Emery

One Year Later: The Yates Memo, False Claims Act and Director & Executive Liability

McDermott Will & Emery on

On September 19 and 27, 2016, the US Department of Justice announced two False Claims Act settlements that required corporate executives to make substantial monetary payments to resolve their liability. How will director and...more

Polsinelli

Millennium Health to Pay $256 million in False Claims Act Settlement

Polsinelli on

Millennium Health, one of the nation’s largest urine drug testing laboratories, has agreed to pay the government $256 million to resolve claims that it violated the Federal False Claims Act (“FCA”). The Settlement...more

Polsinelli

Tuomey Resolves Stark Law and False Claims Act Judgment for $72.4 Million

Polsinelli on

The Department of Justice announced on October 16, 2015 a settlement agreement with Tuomey Healthcare System that resolves a $237 million judgment against the system involving claims submitted to the Medicare program in...more

Mintz

Mintz Levin Health Care Qui Tam Update: Recently Unsealed Whistleblower Cases: October 2015

Mintz on

Trends & Analysis: ..We have identified 15 health care–related qui tam cases that were unsealed since our last Qui Tam Update. Of those, 12 were filed from 2012 to the present. All but two cases had been pending more...more

McDermott Will & Emery

Huge Stark Law Hospital Settlements and Physician Culpability - The New Normal Post-Tuomey?

McDermott Will & Emery on

After the federal government’s victory against Tuomey Hospital, we have seen an increasing number of large False Claims Act (FCA) settlements with hospitals involving Stark Law allegations. Relators are even citing, as...more

Thomas Fox - Compliance Evangelist

Highway 61 Revisited-Tombstone Blues and Corporate Integrity Agreements

I conclude my tribute to my favorite Bob Dylan album, Highway 61 Revisited with a look at the most surreal song on the disc, Tombstone Blues. I want to use it to contrast the most excellent article that appears today as a...more

Lowndes

Florida Nursing Home Pays Record Settlement to Resolve Federal Anti-Kickback Case

Lowndes on

In a recent case Hebrew Homes Health Network, Inc. and its former president and executive Director agreed to pay $17 million to settle allegations that Hebrew Homes violated the federal anti-kickback statute. According to the...more

Cooley LLP

Blog: Court Holds Corporate Integrity Agreement May Be Basis for Reverse False Claim Liability

Cooley LLP on

This week, a federal district court denied Cephalon Inc.’s (Cephalon) motion to dismiss a third amended complaint filed under the False Claims Act (FCA) by three qui tam relators in United States ex rel. Boise v. Cephalon,...more

Seyfarth Shaw LLP

Record $17M Settlement Of False Claims Act Lawsuit Alleging Doctor Kickbacks

Seyfarth Shaw LLP on

Hailed as “another achievement” for the government’s Health Care Fraud Prevention and Enforcement Action Team (referred to as “HEAT”), the U.S. Department of Justice has announced that a Florida skilled nursing company and...more

Skadden, Arps, Slate, Meagher & Flom LLP

"HHS OIG Issues New Compliance Oversight Guidance for Boards of Directors"

On April 20, 2015, the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) published its “Practical Guidance for Health Care Governing Boards on Compliance Oversight” (the Guidance).1...more

Epstein Becker & Green

Spotlight on Responsibility and Accountability: OIG’s New Compliance Guidance for Health Care Governing Boards

On April 20, 2015, the Office of the Inspector General of the U.S. Department of Health and Human Resources (“OIG”), in collaboration with the American Health Lawyers Association, the Association of Healthcare Internal...more

The Volkov Law Group

Catching Up on the False Claims Act

The Volkov Law Group on

From a corporate risk perspective, if your company is in the financial industry, healthcare, or defense industry, your greatest legal and compliance risk has to be the False Claims Act....more

K&L Gates LLP

Blurring the Lines between False Claims Act Litigation and Putative Federal Malpractice Law: The DOJ Quietly Invokes “Worthless...

K&L Gates LLP on

On October 10, 2014, the United States Department of Justice (“DOJ”) announced a civil settlement agreement (the “Settlement”) with Extendicare Heath Services, Inc. and its subsidiary Progress Step Corporation (collectively,...more

Thomas Fox - Compliance Evangelist

Lessons from GSK in China – Internal Controls, Auditing and Monitoring

One of the questions that GSK will have to face during the next few years of bribery and corruption investigations is how an allegedly massive bribery and corruption scheme occurred in its Chinese operations? The numbers went...more

Baker Donelson

The Self-Referral Disclosure Protocol: Settlement and Enforcement Trends (Presentation)

Baker Donelson on

The Self-referral Disclosure Protocol (SRDP) permits health care providers to voluntarily disclose violations of the federal physician self-referral law, also called the Stark law. Emily Wein has presented a webinar...more

Benesch

The Halifax $85 Million Lesson: Compensation Arrangements Between Hospitals and Physicians Must Be Reviewed

Benesch on

The Department of Justice (“DOJ”) announced another multi-million dollar settlement of alleged False Claims Act violations on March 11, 2014. Specifically, Halifax Hospital Medical Center and Halifax Staffing, Inc. agreed to...more

Brownstein Hyatt Farber Schreck

Halifax Pays $85 Million to Resolve Improper Physician Compensation Arrangement Claims Brought by Employee-Whistleblower

Since January 2009, the DOJ has recovered more than $13.4 billion through False Claims Act cases involving fraud against federal health care programs, and last month, Halifax Hospital Medical Center and Halifax Staffing, Inc....more

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