Tagged: HHS-OIG

HHS-OIG Issues Comprehensive Compliance Guidance that Underscores the Need for a Robust and Independent Compliance Function (Part I of III)

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 these innovations translated into strategies that became essential to the compliance industry. For example, in the 1990s, HHS’ Inspector General (“HHS-OIG”) affirmatively pushed for separation of the legal and compliance functions, resulting in...

Episode 280 — Healthcare Compliance and Fraud

Looking back in time, the compliance field owes a lot to the healthcare industry.  In the 1990s, there was a dramatic explosion in the industry in response to aggressive federal enforcement programs and increasing regulation.  All of a sudden, compliance officers who sat in the backrooms of legal departments were “volunteered” to address proactive compliance.  Federal regulators pushed the compliance function to assume a much...

Justice Department, HHS-OIG and Defense Investigators Bring Flurry of False Claims Act Cases (Part I of V)

The False Claims Act is a powerful enforcement tool.  The Justice Department with its partner agencies are ramping up enforcement efforts.  The Biden DOJ is preparing to implement an aggressive FCA program across healthcare, defense industries and other government contractors.  Combined with this initiative, DOJ recently implemented an antitrust enforcement task force relating to government procurement.  In this environment, companies have to address these risks...

HHS-OIG Warns Drug and Device Companies on Speaker Program Fraud

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.  Copy of Special Alert Here.  HHS-OIG’s Fraud Alert is an important warning to pharmaceutical and medical device companies.  It directly applies to U.S. companies’ domestic speaker programs, but the analysis and observations have...

Webinar: Healthcare Providers — The Need to Enhance Your Ethics and Compliance Program

Webinar: Healthcare Providers — The Need to Enhance Your Ethics and Compliance Program Tuesday, April 10, 2018, 12 Noon EST Sign Up Here Healthcare providers continue to face significant enforcement risks. Federal and state regulation of healthcare providers creates numerous risks, including the possibility of criminal fraud prosecutions. False Claims Act prosecutions continue to threaten healthcare providers with potential parallel criminal and civil proceedings. In...