The March 18, 2019 post of Legal Topics in Healthcare provided a definition of Cooperation Credit when undergoing a False Claims Act (FCA), HIPAA Investigation or the like.  In 2015, Deputy Attorney General Yates issued a memorandum detailing a policy on “individual accountability”.  The memo, Individual Accountability for Corporate Wrongdoing, is known as the

There are principles of full disclosure under civil procedure that do not exist in criminal procedure. In the civil setting, the defendant is entitled to notice of the plaintiff’s case, which gives the defendant a stronger opportunity to formulate a defense and win at dismissal. The goal is to maintain even-handedness, so in the civil

Issues RFI Regarding the Anti-Kickback Statute and Beneficiary Inducements

On August 20, 2018, Inspector General Daniel R. Levinson, from the Office of Inspector General (OIG), HHS issued a request for information (RFI) seeking input from the public on how to address any regulatory provisions that may act as barriers to coordinated care or value-based care.