In a far-reaching action, the Health and Human Services – Office of Inspector General (HHS-OIG) issued a Special Fraud Alert underscoring the “inherent fraud and abuse risks” associated with company-sponsored speaker programs. In this Episode, Michael Volkov reviews the HHS-OIG Fraud Alert. The Episode is available Here.
Novartis and Alcon engaged in separate but significant bribery schemes. Considering the fact that Novartis had a similar violation in 2016 in China involving much of the same conduct, Novartis’ conduct reflects a weak corporate culture of compliance. Novartis’ conduct is all the more troubling given its enforcement record on domestic False Claims Act and anti-kickback prosecutions. Novartis has real compliance and culture problems, apparently...
Medical device and pharmaceutical companies know the risks of conducting business in China. Company after company has had to settle FCPA enforcement actions in China. Many of these enforcement actions include fact patterns that are pretty consistent. At the heart of these bribery cases are distributors who are used to funnel bribery payments to healthcare professionals. The expectations and modes of operation are fairly consistent...
