Healthcare Fraud Defense
Federal and state investigations, False Claims Act defense, and criminal healthcare fraud cases.
California Board of Pharmacy Investigations, Citations and Fines
The California Board of Pharmacy investigates complaints, issues citations and fines, and refers serious violations to a formal ac…
Reading an FCA Settlement Agreement: Covered Conduct and Releases
A guide to how DOJ False Claims Act settlement agreements define Covered Conduct, scope the release, and reserve claims that survi…
OIG Exclusion Release in FCA Settlements
OIG decides, separately from the DOJ settlement, whether to exclude a provider, demand a corporate integrity agreement, or release…
Health Care Fraud Strike Forces: How Cases Begin
How DOJ and HHS-OIG Health Care Fraud Strike Forces are structured, how data referrals and agencies combine, and the early signs a…
Fair Market Value and Commercial Reasonableness Under the Stark Law
Stark Law compensation arrangements must satisfy fair market value and commercial reasonableness as two separate, independently re…
Internal Compliance Complaints That Could Become Qui Tams
How a hotline or email complaint that goes undocumented and unresolved becomes the evidentiary backbone of a False Claims Act qui…
Inpatient Admission Status and the Two-Midnight Rule in FCA Cases
A short inpatient stay that misses Medicare's Two-Midnight Rule can become the fact pattern behind a False Claims Act qui tam case…
DOJ Voluntary Self-Disclosure Policy for Healthcare Companies
The DOJ Criminal Division Corporate Enforcement Policy sets six voluntary self-disclosure conditions and three tiers of credit tha…
Compliance Officer Liability in Healthcare Fraud Cases
Compliance officers can become named witnesses, relators, or certifying signatories in healthcare fraud cases over what they knew…