Category: Fraud and Abuse

Resource Launch: 20 Key Considerations for Implementing an Effective Corporate Compliance Program

Cooley is excited to release a new resource for health care and life sciences companies: 20 Key Considerations for Implementing an Effective Corporate Compliance Program.  This quick reference document provides an overview of key areas that a company should consider as it seeks to implement and improve its corporate compliance programs. […]

HHS OIG Releases Annual Solicitation for New and Modified Anti-Kickback Safe Harbors and for New Special Fraud Alerts

On December 29, 2014, the U.S. Department of Health and Human Services Office of Inspector General (OIG) released its annual solicitation (the “Solicitation”) for proposals and recommendations for developing new and modifying existing safe harbor provisions under the Federal Health Care Program Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)) (the “AKS”), as well […]

HHS OIG Hands Out 2015 Work Plan For Halloween

On Friday October 31, 2014, the U.S. Department of Health & Human Services (HHS) Office of Inspector General (OIG) released its annual “Work Plan” for fiscal year 2015.  The Work Plan is a compilation of the OIG’s plans for new and ongoing reviews and activities (including audits, evaluations, and certain […]

OIG Releases Proposed Rule re: Beneficiary Inducements and Gainsharing Revisions

The Health and Human Services Office of Inspector General (OIG) released today a proposed rule titled, Medicare and State Health Care Programs: Fraud and Abuse; Revisions to Safe Harbors under the Anti-Kickback Statute, and Civil Monetary Penalty Rules Regarding Beneficiary Inducements and Gainsharing.  The 94-page proposed rule is expected to be published tomorrow in the […]

OIG Releases Special Advisory Bulletin and Report on Copayment Coupons

Earlier this week, the U.S. Department of Health and Human Services Office of Inspector General (OIG) released a Special Advisory Bulletin titled, Pharmaceutical Manufacturer Copayment Coupons (Bulletin), and a report titled, Manufacturer Safeguards May Not Prevent Copayment Coupon Use for Part D Drugs (Report).  Copayment coupons are offered by pharmaceutical manufacturers in many […]

DOJ Announces Recently Implemented Procedure for Reviewing False Claims Act Suits for Criminal Prosecution

During a speech at the annual Taxpayers Against Fraud Education Fund conference this week, Assistant Attorney General Leslie R. Caldwell announced that the U.S. Department of Justice’s (DOJ) Criminal Division “recently implemented a procedure so that all new qui tam complaints are shared by the Civil Division with the Criminal Division as soon […]

Subcommittee on Oversight and Investigations Holds “Medicare Program Integrity: Screening Out Errors, Fraud and Abuse” Hearing

On June 25, 2014, the U.S. House Energy and Commerce Subcommittee on Oversight and Investigations held a hearing, “Medicare Program Integrity: Screening Out Errors, Fraud, and Abuse.” During the hearing, subcommittee members heard testimony from administration officials from the Centers for Medicare and Medicaid Services (“CMS”), the Office of Inspector […]