Articles and Blogs

Compliance

DOJ’S 2019 False Claims Act Recoveries Total More Than $3 Billion

[01/15/20]

Posted on January 15, 2020 in Compliance, Health Law News

Published by: Hall Render

On January 9, 2020, the Department of Justice (“DOJ”) announced that it collected over $3 billion in settlements and judgments under the False Claims Act (“FCA”) in the federal fiscal year 2019. The FCA has historically been the government’s primary tool for combatting perceived fraud, waste and abuse in the health care system, and... READ MORE

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Violations of Patient Privacy on Social Media Will Result in HIPAA Fines

[10/04/19]

Posted on October 4, 2019 in Compliance, Health Information Technology

Published by: Hall Render

On October 2, 2019, the Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced that a Texas dental practice (“Practice”) will settle potential violations of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) by paying a civil penalty of $10,000 and adopting a corrective action plan. A patient of... READ MORE

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New DOJ Guidance for Antitrust Compliance Programs: Why Health Care Entities Need Antitrust Focus

[09/20/19]

Posted on September 20, 2019 in Compliance, Health Law News

Published by: Hall Render

On July 11, 2019, the Antitrust Division of the DOJ (“Division”) announced a new initiative aimed at encouraging robust corporate antitrust compliance programs. The Division’s initiative incentivizes compliance programs by establishing that firms charged criminally for antitrust violations will be given credit in charging and sentencing recommendations if they have effective corporate antitrust compliance... READ MORE

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Defendants Successful in FCA Action Alleging Donuts for Referrals

[08/06/19]

Posted on August 6, 2019 in Compliance, Health Law News

Published by: Hall Render

Last week, a federal district court in Illinois entered judgment for Defendants in an FCA action against a self-proclaimed “one stop shop” health care referral management company, alleging anti-kickback and FCA violations for its arrangement with a care coordination organization for low-income seniors.[1] Originally filed in 2016, this case highlights how even an FCA... READ MORE

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DOJ Self-Disclosure and Cooperation Credit

[05/17/19]

Posted on May 17, 2019 in Compliance, False Claims Act Defense

Published by: Hall Render

The DOJ’s recent revisions to its Justice Manual created a new path for self-disclosing potential fraud to the government – one which is unique in its ability to defray the costs of potential False Claims Act violations. In 2015, Deputy Attorney General Sally Quillian Yates released a memo entitled Individual Accountability for Corporate Wrongdoing, more... READ MORE

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Department of Justice Updates Compliance Program Guidance

[05/13/19]

Posted on May 13, 2019 in Compliance, Health Law News

Published by: Hall Render

On April 30, 2019, the U.S. Department of Justice (“DOJ”) released an updated version of is guidance known as “The Evaluation of Corporate Compliance Programs” (“2019 Guidance Document”). This document provides actionable guidance for health care providers seeking to assess and enhance their compliance programs. The DOJ’s updates emphasize the government’s view that not... READ MORE

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OIG Requests Information from Stakeholders to Expand Anti-Kickback Statute and Civil Monetary Penalty Safe Harbors

[09/14/18]

Posted on September 14, 2018 in Compliance, Health Law News

Published by: Hall Render

On August 27, 2018, the Department of Health and Human Services (“HHS”) Office of Inspector General (“OIG”) published a Request for Information (“RFI”) regarding the Anti-Kickback Statute (“AKS”) and Civil Monetary Penalties Law (“CMP”). The RFI, published as a result of HHS’s desire to transition the current health care system to one that pays... READ MORE

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