Archives: Healthcare

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How to Use Data Mining for Compliance

Government uses data mining to select targets for enforcement actions. Your company can use data mining for compliance. Hear tips and insights in an eleven minute podcast in “Compliance Perspectives,” from the Society of Corporate Compliance and Ethics (SCCE).  SCCE is a member-based association providing education and news updates for ethics and compliance professionals. To listen to the podcast, click here.… Continue Reading

Exclusion from Healthcare Programs for a Misdemeanor?

Even a misdemeanor guilty plea can have far reaching ramifications in the healthcare industry. The Sixth Circuit recently upheld a decision of the Department of Health and Human Services (HHS) that a healthcare provider was subject to mandatory exclusion following a guilty plea to misdemeanor misbranding. As the court recognized, trial counsel had anticipated this … Continue Reading

Applying Escobar — Decisions on Materiality, Falsity and Other Issues

June 16, 2017, marks the one-year anniversary of the precedent-setting U.S. Supreme Court decision in Universal Health Services v. United States ex rel. Escobar (Escobar), which approved the implied false certification theory as a basis for liability under the False Claims Act (FCA). Because the decision impacts every provider who supplies goods and services to … Continue Reading
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