Category: General

General

26 Oct, 2023

BioTek and Chaitanya Gadde, its CEO, Agreed to Pay $20 Million, and Dr. David Tabby, Agreed to Pay $480K to Resolve Anti-Kickback Violations

The reach of the Anti-Kickback Statute and the False Claims Act is broad.  As a result, AKS liability is a real and significant risk for healthcare companies and providers. Healthcare companies and providers have to resolve such claims because of the potential consequence of exclusion from “federal health care programs,” which is essentially a death sentence for any covered company that received federal reimbursement. In...

General

24 Oct, 2023

The Evolution of the Compliance Profession

One of the benefits of old(er) age is perspective and experience.  (As we age, we have to find the positive reasons to tout).  If there is one thing (of many) the compliance profession has demonstrated, it is that compliance professionals are nimble. It comes with the territory.  Building and maintaining a compliance program, requires compliance professionals to adjust their focus and prioritize resources and time...

General

24 Oct, 2023

Cigna Group Falls Under the False Claims Axe and Pays Over $172 Million for Abuse of Medicare Advantage Program

As if corporate healthcare businesses needed an enforcement reminder, DOJ recently announced a settlement with Cigna Group for $172 million to resolve claims that Cigna exaggerated patient illnesses to extract more money from the Medicare Advantage Program. Under the Medicare Advantage (MA) Program, also known as Medicare Part C, Medicare beneficiaries have the option of obtaining their Medicare-covered benefits through private insurance plans called MA...

General

23 Oct, 2023

OFAC Provides Venezuela with Sanctions Relief, Authorizes Certain Transactions in the Oil and Gas Industry

Matt Stankiewicz, Partner at The Volkov Law Group PC, rejoins us for an important blog posting concerning OFAC’s recent relaxation of the Venezuela Sanctions Program. Matt can be reached at [email protected]. On October 18, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) took several steps to provide Venezuela with some limited relief from its sanctions.  The relief includes General Licenses authorizing...

General

20 Oct, 2023

DOJ Revises Standard Ethics and Compliance Requirements Used in Settlements

Daniela Melendez, an Associate at The Volkov Law Group, an Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoin us for another posting on DOJ’s recent modifications to its compliance requirements. Daniela can be reached at [email protected] and Alex can be reached at [email protected]. As The Volkov Law Group previously noted in the context of a blog post authored by Michael Volkov,  the U.S....

General

19 Oct, 2023

Practical Steps to Mitigate Electronics Communications Risks: “This is the Way” (Part III of III)

I always welcome any chance to use references to The Mandalorian series on Disney (or Ashoka for that matter) in the compliance arena.  My take on the issue of electronic communications and ephemeral messaging is rooted in practical, risk-based strategies to avoid potential legal consequences that appear to be steadily growing as DOJ and courts deal with the issues. So, “This is the Way,” at...

General

18 Oct, 2023

Electronic Communications Risks — DOJ Enters the Fray in March 2023 (Part II of III)

Just to play devil’s advocate (or perhaps to push my agenda), I have conflicting views on corporate use of ephemeral messaging applications.  On the one hand, I understand the importance of managing electronics communications data, prioritizing the preservation of relevant data, and reducing attendant costs from managing ever-growing amounts of electronic data.  On the other hand, as a former prosecutor and now defense counsel, I...

General

17 Oct, 2023

Electronic Communications Risks — Asking the Critical Questions? (Part I of III)

Honestly, I have been avoiding this topic since it presents a real morass of risks and potential traps for the unwary company and Chief Compliance and Chief Legal Officers.  When I first examined the issue, I understood DOJ’s frustration.  If bad actors can escape detection and subsequent punishment (internal or external) by using ephemeral messaging applications to delete illegal or improper communications, companies should simply...

General

13 Oct, 2023

OFAC Ramps Up Price Cap Enforcement as Coalition Publishes Compliance Advisory for Maritime Oil Industry

Sam Finkelstein rejoins us for a posting on OFAC’s recent enforcement steps and guidance on Russian Oil Sanctions and the Maritime Industry. Sam can be reached at [email protected]. It looks like the days of Russia’s so-called “shadow fleet” are numbered. The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced Thursday that it had imposed sanctions on two entities, and identified as...

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