This Webcast Will Begin Shortly
|
|
- Pierce McKenzie
- 5 years ago
- Views:
Transcription
1 This Webcast Will Begin Shortly If you have any technical problems with the Webcast or the streaming audio, please contact us via at: Thank You! 1
2 How to Avoid False Claims Act Exposure: Effective Tools for Prevention, Investigation, and Resolution Presented By: Deborah Goldstock Ringel, Senior Legal Counsel, Accenture LLP Steven Kaufmann, Partner, Morrison & Foerster LLP Stacey Sprenkel, Partner, Morrison & Foerster LLP September 16, 2015
3 Civil False Claims Act - 31 USC 3729 The Civil False Claims Act creates liability against any person who knowingly submits a false claim to the government; knowingly makes a false record or statement to get a false claim paid by the government; conspires with another to violate the FCA Knowingly actual knowledge deliberate ignorance of the truth or falsity of the information reckless disregard of the truth or falsity of the information Implied Certification an entity that merely requests payment from the government without disclosing a known breach of a material term can violate the FCA 3
4 States With Their Own False Claims Statutes 4
5 FCA: DOJ s Civil Weapon of Choice Substantial exposure $45 billion in federal civil recoveries since 1987 Treble damages (i.e., three times actual damages) Fines of $5,500 to $11,000 for each false claim Attorneys fees and costs to prevailing plaintiff Suspension and debarment 5
6 Recent Flood of FCA Lawsuits More than 700 new FCA matters initiated each year In 2014, 804 suits were filed, more than 700 were filed by qui tam relators Vast majority of these are brought by qui tam relators $5.7 billion in FCA settlements and judgments in 2014 alone $435M went to qui tam relators 87% Qui Tam Relators 6
7 Managing Your Risk ü Tone from the top Establish an effective program for complying with laws and regulations Supervision Policies and procedures for audits Conduct regular trainings Conduct periodic compliance audits Privilege Emphasize importance of regular timekeeping and billing under government contracts Maintain close oversight of subcontractors and their billing practices Include indemnification provisions in government subcontracts 7
8 Managing Your Risk (cont d.) ü Tone from the top again Detailed reporting procedures, including procedures to evaluate and address issues when identified Ethics hotline In-person reporting Training and Support Conduct internal investigations when necessary Secure your information Closely monitor settlements and unsealed cases Who is getting creative? Obtain insurance against FCA claims As a practical matter uncommon and expensive 8
9 Effective Investigations When an Issue Arises Critical decisions need to be made quickly: Is an investigation warranted, and what is the appropriate scope? Scope should be defined but flexible Do you have a self-disclosure obligation? If so, what is the standard requiring self-disclosure, and what constitutes a timely self-disclosure? 9
10 Who Supervises and Conducts the Investigation? Who supervises? Management? The Board? Who investigates? In-House Counsel? Outside Counsel? Independent/Special Counsel? 10
11 Engaging Outside Consultants Forensic accountants E-Discovery consultants Subject matter consultants Industry experts Private investigators 11
12 Protecting the Privileged Nature of the Investigation Take steps to preserve privilege Witness Interviews Notes Documenting Conclusions Balancing protecting the privilege with government cooperation 12
13 Other Key Considerations To disclose or not to disclose (if no disclosure obligation)? And when to disclose? Conducting interviews Who to interview? When to interview? Who should be present? Potential Whistleblowers Remediation 13
14 DOJ: No Plans to Slow Down Plans to commit even more resources to its Fraud Section to investigate and file FCA cases Diversifying its enforcement activities to ensure record recoveries Plans to systematically pursue criminal charges in tandem with civil FCA suits Renewed emphasis on non-monetary remedial measures 14
15 From Civil to Criminal Enforcement AAG Caldwell: DOJ will bring unparalleled experience prosecuting health care fraud, procurement fraud, and financial fraud to investigations and prosecutions that stem from allegations in [FCA] suits. All new qui tam complaints are shared by the Civil Division with Criminal Division as soon as the cases are filed. DOJ seeking admissions of misconduct and sanctions against individuals as part of settlements. 15
16 Dangers of DOJ Settlements Admissions Debarment Criminal Charges 16
17 Decision Points Compliance Program Learning of a Problem Internally Discovered Government Outreach (CID) Government Investigation Agency Review DOJ Possibly Qui Tam Driven Litigation Filed or Unsealed Early Settlement Motion to Dismiss 17
18 Settlement Considerations What s the price Ability to pay Scope of the release conduct and parties Avoiding suspension or debarment Remediation corporate integrity program; monitors; ongoing cooperation Government objections or relator s objections Multi-jurisdiction settlements Relator s attorney fees Collateral litigation 18
19 For More Information: Steven Kaufmann (202) Stacey Sprenkel (415)
20 Thank you for attending another presentation from ACC s Webcasts Please be sure to complete the evaluation form for this program as your comments and ideas are helpful in planning future programs. If you have questions about this or future webcasts, please contact ACC at webcast@acc.com This and other ACC webcasts have been recorded and are available, for one year after the presentation date, as archived webcasts at 20
NewYork-Presbyterian Hospital Sites: All Centers Hospital Policy and Procedure Manual Number: D160 Page 1 of 8
Page 1 of 8 TITLE: FEDERAL DEFICIT REDUCTION ACT OF 2005 FRAUD AND ABUSE PROVISIONS POLICY: NewYork- Presbyterian Hospital (NYP or the Hospital) is committed to preventing and detecting any fraud, waste,
More informationClinical and Administrative Policies and Procedures
Clinical and Administrative Policies and Procedures Purpose: Centerstone is committed to its role in preventing health care fraud and abuse and complying with applicable state and federal law related to
More informationFalse Claims Act and Mandatory Disclosure Requirements for Federal Contractors
False Claims Act and Mandatory Disclosure Requirements for Federal Contractors Presenters: Robert T. Rhoad, Esq. & Dalal Hasan, Esq. 2012 Crowell & Moring LLP All Rights Reserved False Claims Act: Recent
More informationFalse Claims Act and Mandatory Disclosure Requirements for Federal Contractors
False Claims Act and Mandatory Disclosure Requirements for Federal Contractors Presenters: Robert T. Rhoad, Esq. & Dalal Hasan, Esq. 2012 Crowell & Moring LLP All Rights Reserved False Claims Act: Recent
More informationFalse Claims Liability, Anti-Retaliation Protections, and Detecting and Responding to Fraud, Waste, and Abuse
False Claims Liability, Anti-Retaliation Protections, and Detecting and Responding to Fraud, Waste, and 1. SCOPE 1.1 System-wide, including Marshfield Clinic Health System (MCHS), Inc. and its affiliated
More informationThe False Claims Act. False Claims Act Basics (I)
The False Claims Act Basic Concepts, Recent Trends, and Strategies for Minimizing Risks Philip D. Robben February 26, 2013 False Claims Act Basics (I)! Imposes liability on those who submit false claims
More informationThis policy applies to all employees, including management, contractors, and agents. For purpose of this policy, a contractor or agent is defined as:
Policy and Procedure: Corporate Compliance Topic: Purpose: Choice of NY is committed to prompt, complete, and accurate billing of all services provided to individuals. Choice of NY and its employees, contractors,
More informationCorporate Compliance Topic: False Claims Act and Whistleblower Provisions
Purpose: INDEPENDENT LIVING, Inc. (also referred to as ILI, ) is committed to prompt, complete and accurate billing of all services provided to individuals. ILI and its employees, contractors and agents
More informationMFA COMPLIANCE 2016: UNDERSTANDING INSURANCE AND LIABILITY: A FOCUS ON D&O, CYBERSECURITY AND POLICY REVIEWS
MFA COMPLIANCE 2016: UNDERSTANDING INSURANCE AND LIABILITY: A FOCUS ON D&O, CYBERSECURITY AND POLICY REVIEWS Presented by: Lynda A. Bennett Chair, Insurance Recovery Group LOWENSTEIN SANDLER LLP 973.597.6338
More informationCardinal McCloskey Community Services. Corporate Compliance. False Claims Act and Whistleblower Provisions
Cardinal McCloskey Community Services Corporate Compliance False Claims Act and Whistleblower Provisions Purpose: Cardinal McCloskey Community Services is committed to prompt, complete and accurate billing
More informationSOUTH NASSAU COMMUNITIES HOSPITAL One Healthy Way, Oceanside, NY 11572
SOUTH NASSAU COMMUNITIES HOSPITAL One Healthy Way, Oceanside, NY 11572 POLICY TITLE: Compliance with Applicable Federal and State False Claims Acts POLICY NUMBER: OF-ADM-232 DEPARTMENT: Hospital-wide BACKGROUND/PURPOSE
More informationMandatory Disclosures: Best Practices for Protecting Your Company s Interests in the Current Compliance Environment
Mandatory Disclosures: Best Practices for Protecting Your Company s Interests in the Current Compliance Environment Wednesday, May 17, 2017 12:00pm 1:30pm ET MODERATOR: Paul A. Debolt SPEAKERS: Dismas
More informationFederal and State False Claims Act Education Policy
*TEAMHealth Policies and Procedures Policy Name: Federal and State False Claims Act Education Policy Effective Date: January 1, 2017 Approved By: Executive Compliance Committee Replaces Policy Dated: January
More informationDefending Corporations and Individuals in Government Investigations Ethics & Whistleblower Issues In Investigations
Defending Corporations and Individuals in Government Investigations Ethics & Whistleblower Issues In Investigations Daniel J. Fetterman Mark P. Goodman Reid Figel Daniel Karson Patrick Pericak September
More informationMENTAL HEALTH MENTAL RETARDATION OF TARRANT COUNTY. Board Policy. Number A.3 July 31, 2001 COMPLIANCE PLAN
MENTAL HEALTH MENTAL RETARDATION OF TARRANT COUNTY Board Policy Board Policy Adopted: Number A.3 July 31, 2001 OVERVIEW COMPLIANCE PLAN As adopted by the Board of Trustees on July 31, 2001 The Board of
More informationThe False Claims Act and Financial Institutions: A New Role for an Old Statute
The False Claims Act and Financial Institutions: A New Role for an Old Statute D. Jean Veta Ethan M. Posner Benjamin J. Razi July 18, 2012 Agenda 1. Background on False Claims Act 2. FCA in healthcare
More informationReverse FCA Cases Rise With 'America First' Trade Policies
Portfolio Media. Inc. 111 West 19 th Street, 5th Floor New York, NY 10011 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com Reverse FCA Cases Rise With 'America First'
More informationFEDERAL DEFICIT REDUCTION ACT POLICY
A. Introduction. FEDERAL DEFICIT REDUCTION ACT POLICY Partnership for Children of Essex, Inc. (referred to herein as the Organization ) has instituted this Federal Deficit Reduction Act Policy as part
More informationThe False Claims Act and Off-Label Promotion: Understanding and Minimizing the Risks for Pharmaceutical Manufacturers
4th Annual Pharmaceutical Regulatory Congress November 12, 2003 The False Claims Act and Off-Label Promotion: Understanding and Minimizing the Risks for Pharmaceutical Manufacturers John T. Bentivoglio
More informationThis Webcast Will Begin Shortly
This Webcast Will Begin Shortly If you have any technical problems with the Webcast or the streaming audio, please contact us via email at: webcast@acc.com Thank You! SEC Enforcement Trends, the Dodd-Frank
More informationThis Webcast Will Begin Shortly
This Webcast Will Begin Shortly If you have any technical problems with the Webcast or the streaming audio, please contact us via email at: webcast@acc.com Thank You! THE FCPA IN 2018 NEW POLICIES, NEW
More informationCORPORATE COMPLIANCE POLICY AND PROCEDURE
Title: False Claims Act Policy Policy # 1011 Sponsor: Corporate Approved by: Kenneth J. Sodaro, Esq., Vice President, General Counsel & Corporate Secretary, Interim Officer Issued: Page: 1 of 5 June 25,
More informationAnti-Fraud Policy. The following non-exhaustive list provides a few examples of fraud that this Policy is designed to prevent and detect:
Introduction Anti-Fraud Policy In some instances, Medicaid pays for some or all of the services provided. It is the policy of Helper s Inc. to comply with all applicable federal, state and local laws and
More informationSection (Primary Department) Medicaid Special Investigations Unit. Effective Date Date of Last Review 01/30/2015 Department Approval/Signature :
Medicaid Special Investigations Unit Medicaid Business Unit Date of Last Revision Dept. Approval Date Policy applies to Medicaid products offered by health plans operating in the following State(s) California
More informationC. Enrollees: A Medicaid beneficiary who is currently enrolled in the MCCMH PIHP.
professionally recognized standards for health care. It also includes beneficiary practices that result in unnecessary cost to the Medicaid program. 42 CFR 455.2 B. CMS: Centers for Medicare & Medicaid
More informationSUNY DOWNSTATE MEDICAL CENTER POLICY AND PROCEDURE. No:
SUNY DOWNSTATE MEDICAL CENTER POLICY AND PROCEDURE Subject: Complying with the Deficit Reduction Act of 2005: Detection & Prevention of Fraud, Waste & Abuse Page 1 of 4 Prepared by: Shoshana Milstein Original
More informationEffective Date: 5/31/2007 Reissue Date: 10/08/2018. I. Summary of Policy
Issuing Department: Internal Audit, Compliance, and Enterprise Risk Management Preventing Fraud, Waste, and Abuse: Federal and State False Claims and False Statements Effective Date: 5/31/2007 Reissue
More informationEffective Date: 1/01/07 N/A
North Shore-LIJ Health System is now Northwell Health POLICY TITLE: Detecting and Preventing Fraud, Waste, Abuse and Misconduct POLICY #: 800.09 System Approval Date: 03/30/2017 Site Implementation Date:
More informationThis Webcast Will Begin Shortly
This Webcast Will Begin Shortly If you have any technical problems with the Webcast or the streaming audio, please contact us via email at: webcast@acc.com Thank You! 1 Whistleblowers: What US and Multinational
More informationContractors in the Crosshairs: Investigations Passing Government Scrutiny
Westlaw Journal Government Contract Litigation News and Analysis Legislation Regulation Expert Commentary VOLUME 29, issue 4 / june 22, 2015 Expert Analysis Contractors in the Crosshairs: Investigations
More informationOVERVIEW: Avoiding Government Contracting Compliance Pitfalls, Bid Protests and Claims
OVERVIEW: Avoiding Government Contracting Compliance Pitfalls, Bid Protests and Claims Bill Walsh, Venable LLP 8010 Towers Crescent Drive, Suite 300 Tysons Corner, VA 22182 703-760-1685 WLWalsh@Venable.com
More informationMandatory Disclosure: A New Reality Angela Styles Shauna Alonge Gunjan Talati November 18, 2008
Mandatory Disclosure: A New Reality Angela Styles Shauna Alonge Gunjan Talati November 18, 2008 2008 Crowell & Moring LLP All Rights Reserved Today s Agenda Background New Cause for Suspension/Debarment
More informationWHISTLEBLOWERS. Labor and Employment Briefing May 19, 2016 Robert E. Hauberg, Jr.
WHISTLEBLOWERS Labor and Employment Briefing May 19, 2016 Robert E. Hauberg, Jr. WHAT IS A PUBLIC EMPLOYEE WHISTLEBLOWER - Federal Whistleblower Protection Act of 1989, Pub. L 101-12, 5 U.S.C. 1201 et
More informationAGENCY POLICY. IDENTIFICATION NUMBER: CCD001 DATE APPROVED: Nov 1, 2017 POLICY NAME: False Claims & Whistleblower SUPERSEDES: May 18, 2009
IDENTIFICATION NUMBER: CCD001 DATE APPROVED: Nov 1, 2017 POLICY NAME: False Claims & Whistleblower SUPERSEDES: May 18, 2009 Provisions OWNER S DEPARTMENT: Compliance APPLICABILITY: All Agency Programs
More informationFederal Deficit Reduction Act of 2005, Section 6032 on Fraud, Waste, and Abuse
Policy Number: 4003 Page: 1 of 8 POLICY: It is the policy of Bridgeway Rehabilitation Services, Inc. to obey all federal and state laws and to implement and enforce procedures to detect and prevent fraudulent
More informationGovernment Documents Regarding Civil Fraud and White-Collar Offenses
Government Documents Regarding Civil Fraud and White-Collar Offenses U.S. Department of Justice Office of the Deputy Attorney General The Deputy Attorney General Washington, DC 20530 June 3, 1998 MEMORANDUM
More informationChapter 41 - Legal and Other Proceedings
Chapter 41 - Legal and Other Proceedings Authoritative Sources FAR 31.205-47 Costs Related to Legal and Other Proceedings FAR31.205-33 Professional and Consultant Service Costs FAR 31.204 Application of
More informationFALSE CLAIMS ACT ENFORCEMENT: RECENT TRENDS AND STEPS TO ENSURE COMPLIANCE AND AVOID FRAUD ALLEGATIONS
FALSE CLAIMS ACT ENFORCEMENT: RECENT TRENDS AND STEPS TO ENSURE COMPLIANCE AND AVOID FRAUD ALLEGATIONS The Carolinas Center s 39 th Annual Hospice & Palliative Care Conference Columbia, SC Presenters:
More informationPolicy to Provide Information for Combating Fraud, Waste and Abuse and the Ability of Employees to Report Wrongdoing
1 of 8 and Abuse and the Ability of Employees to Report Wrongdoing 1. Purpose The purpose of this policy is to provide information for combating fraud, waste and abuse and the ability of employees to report
More informationSEC Adopts Final Rules on the Dodd-Frank Whistleblower Program But Is This a Game Changer?
W. Scott Sorrels June 22, 2011 SEC Adopts Final Rules on the Dodd-Frank Whistleblower Program But Is This a Game Changer? Let s Make a Deal Rules provide for a bounty of 10% to 30% of the aggregate monetary
More informationIn an environment of heightened federal enforcement
THE GOVERNANCE COUNSELOR CAPITAL MARKETS & CORPORATE GOVERNANCE Ocean Photography/Veer Board-Driven Internal Investigations In her regular column on corporate governance issues, Holly Gregory discusses
More informationCLIENT ALERT: NEW FAR REQUIREMENTS FOR MANDATORY DISCLOSURE
311 California Street San Francisco, CA 94104 www.rjo.com 415.956.2828 415.956.6457 fax www.rjo.com CLIENT ALERT: NEW FAR REQUIREMENTS FOR MANDATORY DISCLOSURE On December 12, 2008, a major revision to
More informationU.S. v. Sulzbach: Government Theories, Potential Defenses, and Lessons Learned
U.S. v. Sulzbach: Government Theories, Potential Defenses, and Lessons Learned Presented By: David O Brien Christine Rinn Michael Paddock HOOPS 2007 - Washington, DC October 15-16 Background June 1994:
More informationPotential Perils of Using New Media in Marketing and Promotion. Christina M. Markus (202)
Potential Perils of Using New Media in Marketing and Promotion Christina M. Markus (202) 626-2926 cmarkus@kslaw.com FACEBOOK Using Facebook to develop online community TWITTER Using Twitter as another
More informationHELAINE GREGORY, ESQ.
HCCA Puerto Rico Regional Annual Conference May 3, 2013 MODERATOR HELAINE GREGORY, ESQ. HCCA CONFERENCE CO-CHAIR PANEL DOROTHY DEANGELIS FTI CONSULTING MAITE MORALES MARTINEZ, ESQ., LL.M. MEDICAL CARD
More informationWhat To Do When The Feds Come Knocking. Christine Williams Dave Taylor
What To Do When The Feds Come Knocking Christine Williams Dave Taylor February 5, 2013 Christine Williams Anchorage, AK (907) 263-6931 Cwilliams@perkinscoie.com Presenters Dave Taylor Seattle, WA (206)
More informationProtecting the Navy from Acquisition Fraud Through Detection, Deterrence and Recovery
Protecting the Navy from Acquisition Fraud Through Detection, Deterrence and Recovery AIO Mission Provide a Department of the Navy wide program to deter fraud to the maximum extent possible, detect fraud
More informationR E P R I N T JAN-MAR Inside this issue: The evolving role of the chief risk officer Managing your company s regulatory exposure
R E P R I N T RC & risk compliance & NEW DOJ POLICIES MAY HELP COMPANIES BETTER NAVIGATE FALSE CLAIMS ACT INVESTIGATIONS REPRINTED FROM: RISK & COMPLIANCE MAGAZINE OCT-DEC 2018 ISSUE RC & risk & compliance
More informationAvoiding FCA Litigation:
Avoiding FCA Litigation: Compliance Best Practices from Practitioners, Inside Counsel, and Consultants Weil s False Claims Act Institute March 12, 2014 Introductory Remarks: What is the FCA, and Why Does
More informationThe Anesthesia Company Model: Frequently Asked Questions
The Anesthesia Company Model: Frequently Asked Questions 1. What is the situation in Florida? Florida-specific Issues For several years, FSA members have been contacting the society with reports of company
More informationThe False Claims Act: What CFMs Need to Know
Copyright 2013 by the Construction Financial Management Association. All rights reserved. This article first appeared in CFMA Building Profits. Reprinted with permission. BY DAVID R. COOK & MARK V. HANRAHAN
More informationReporting and Returning Overpayments. The 60-Day Repayment Window
Reporting and Returning Overpayments The 60-Day Repayment Window James A. Robertson, Esq. jrobertson@mdmc-law.com John W. Kaveney, Esq. jkaveney@mdmc-law.com Affordable Care Act requires: A person Who
More informationConducting Effective Compliance Investigations
Conducting Effective Compliance Investigations Roberto M. Braceras February 12, 2016 Damian Wilmot Vice President, Litigation Vertex Pharmaceuticals Incorporated OVERVIEW There are real-life scenarios
More informationFalse Claims Act Enforcement in the Managed Care Space: Recent Trends and Proactive Compliance Tips
False Claims Act Enforcement in the Managed Care Space: Recent Trends and Proactive Compliance Tips Thomas Clarkson* U.S. Attorney s Office Southern District of Georgia Scott R. Grubman Chilivis Cochran
More informationDefending Whistleblower Cases: An Advanced View From the Trenches. Gregory M. Luce Jones Day
Defending Whistleblower Cases: An Advanced View From the Trenches Gregory M. Luce Jones Day www.hcca-info.org 888-580-8373 Whistleblower Actions False Claims Act Statute prohibiting fraud against the government
More informationAGC TAX AND FISCAL AFFAIRS
AGC TAX AND FISCAL AFFAIRS Federal Government Contracting Mandatory Disclosure and Compliance Requirements for Federal Contractors March 17, 2010 Stephen B. Shapiro, Esq. Copyright 2009 Holland & Knight
More informationFAST BREAK: GOVERNMENT ENFORCEMENT OF INDIVIDUAL ACCOUNTABILITY. Katie McDermott Jacob Harper February 28, Morgan, Lewis & Bockius LLP
FAST BREAK: 2015 Morgan, Lewis & Bockius LLP GOVERNMENT ENFORCEMENT OF INDIVIDUAL ACCOUNTABILITY Katie McDermott Jacob Harper February 28, 2017 2015 Morgan, Lewis & Bockius LLP Discussion Agenda Individual
More informationCoverage Issues Relating To Claims Under The False Claims Act
Coverage Issues Relating To Claims Under The False Claims Act May 2, 2017 Stephen A. Wood Chuhak & Tecson, P.C. 30 South Wacker, Ste 2600 Chicago, IL 60606 swood@ Direct Dial: 312-201-3400 Facsimile: 312-444-9027
More informationThe Stark Law and Self-Disclosure:
The Stark Law and Self-Disclosure: What Should You Do After Discovering a Potential Stark Violation? Healthcare Horizons Webinar Series September 25, 2012 Husch Blackwell LLP Welcome Brian Bewley, Partner
More informationDEFICIT REDUCTION ACT AND FALSE CLAIMS POLICY INFORMATION FOR All NEW YORK WORKFORCE MEMBERS
DEFICIT REDUCTION ACT AND FALSE CLAIMS POLICY INFORMATION FOR All NEW YORK WORKFORCE MEMBERS The Company is committed to preventing health care fraud, waste and abuse and complying with applicable state
More informationSPECIAL COMPLIANCE AND ETHICS CONSIDERATIONS FOR CONTRACTORS. Trina Fairley Barlow David Robbins Gail Zirkelbach Jana del Cerro Nkechi Kanu
SPECIAL COMPLIANCE AND ETHICS CONSIDERATIONS FOR CONTRACTORS Trina Fairley Barlow David Robbins Gail Zirkelbach Jana del Cerro Nkechi Kanu 71 Civil False Claims Act Civil False Claims Act ( FCA ) 31 U.S.C.
More informationCORPORATE COMPLIANCE POLICY AND PROCEDURE
Title: Fraud Waste and Abuse Laws in Health Care Policy # 1011 Sponsor: Corporate Compliance Approved by: Russell J. Matuszak, Interim Director, Corporate Compliance and Chief Privacy Officer Issued: Page:
More informationIssues In Internal Investigations for Company Counsel in the Post-Enron Era September 13, 2006
Issues In Internal Investigations for Company Counsel in the Post-Enron Era September 13, 2006 2005 Morrison & Foerster LLP All Rights Reserved Overview Risks and benefits of internal investigations When
More informationAnatomy of a Voluntary Disclosure
Anatomy of a Voluntary Disclosure Association of Corporate Counsel March 15, 2011 Christopher A. Myers (703-720-8038) Chris.Myers@hklaw.com Kwamina T. Williford (202-828-1857) Kwamina.Williford@hklaw.com
More informationFalse Claims Act Alert
False Claims Act Alert March 21, 2018 Key Points In an unusual move, the government has decided to pursue a False Claims Act (FCA) suit against a private equity firm based on an alleged commission scheme
More informationThe Practice and Pitfalls of Internal Investigations:
The Practice and Pitfalls of Internal Investigations: How to Keep Both Your License and Your Sanity Mark Bartlett Davis Wright Tremaine LLP 1 When Do You Need to Investigate? Red Flags Questionable accounting
More informationDFARS Cyber Compliance And Potential For FCA Risk
DFARS Cyber Compliance And Potential For FCA Risk December 18, 2017 By Colleen Brown, Robert Conlan and Christopher Fonzone For well over a year, defense contractors have had New Year s Eve 2017 circled
More informationWYOMING PRIMARY CARE ASSOCIATION (WYPCA) Document Destruction and Whistle-Blower/Code of Conduct Policy
WYOMING PRIMARY CARE ASSOCIATION (WYPCA) Document Destruction and Whistle-Blower/Code of Conduct Policy Adopted by the WYPCA Board of Directors on January 21, 2015. The Sarbanes-Oxley Act, which was signed
More informationCurrent Status: Active PolicyStat ID: Fraud, Waste and Abuse
Current Status: Active PolicyStat ID: 2397820 Policy Scope: Date Of Origin: 06/2015 Last Approved: 07/2016 Last Revised: 07/2016 Next Review: 07/2018 Sponsor: Policy Area: Regulatory Tags: Applicability:
More informationDEFICIT REDUCTION ACT AND FALSE CLAIMS POLICY INFORMATION FOR All MASSACHUSETTS WORKFORCE MEMBERS
DEFICIT REDUCTION ACT AND FALSE CLAIMS POLICY INFORMATION FOR All MASSACHUSETTS WORKFORCE MEMBERS The Company is committed to preventing health care fraud, waste and abuse and complying with applicable
More informationWhistleblower Incentive Program What it Will Mean to You
Cynthia M. Krus, Partner Allegra J. Lawrence-Hardy, Partner Holly H. Smith, Partner Sutherland Asbill & Brennan LLP January 26, 2011 Whistleblower Incentive Program What it Will Mean to You Speakers Cynthia
More informationAccountability Report Card Summary 2013 Hawaii
Accountability Report Card Summary 2013 Hawaii Hawaii has a fairly good state whistleblower law: Scoring only 58 out of a possible 100 points; and Ranking 24 th out of 51 (50 states and the District of
More informationImproving Integrity in Nursing Centers
Improving Integrity in Nursing Centers Susan Edwards Reed Smith LLP AHCA/NCAL s General Counsel Goals of this webinar Introduce you to AHCA/NCAL s Fraud and Abuse Toolkit Provide you with a basic understanding
More informationA CFTC Enforcement Refresher and Overview of Cooperation Credit. By: James G. Lundy and Mary P. Hansen Drinker Biddle & Reath LLP
A CFTC Enforcement Refresher and Overview of Cooperation Credit By: James G. Lundy and Mary P. Hansen Drinker Biddle & Reath LLP Administrative Items The webinar will be recorded and posted to the FIA
More informationThe Salcido Report. False Claims Act Public Disclosure Alert. If you read one thing...
The Salcido Report September 25, 2015 If you read one thing... Launch of a new False Claims Act (FCA) resource The Public Disclosure Alert (PDA) provides expert analysis of latest paradigm shifting FCA
More informationFalse Claims Act and Whistleblower Protections
False Claims Act and Protections Date Implemented: 1/28/2009 Date Reviewed/ Revised: 9/5/2017 Reviewed/ Revised By: SR/KBJ Purpose: To satisfy requirements to provide information and education about False
More informationRisky Business: Protecting the Personal Assets of Ds&Os. Steven Cohen, Marsh Inc. Jay Dubow, Pepper Hamilton LLP Bob Hickok, Pepper Hamilton LLP
Risky Business: Protecting the Personal Assets of Ds&Os Steven Cohen, Marsh Inc. Jay Dubow, Pepper Hamilton LLP Bob Hickok, Pepper Hamilton LLP Thursday, January 28, 2016 Topics Nuts and Bolts - D&O Liability,
More informationTHE NEW YORK FOUNDLING
THE NEW YORK FOUNDLING COMMITMENT TO COMPLIANCE HANDBOOK CODE OF CONDUCT AND COMPLIANCE STANDARDS COMPLIANCE PROGRAM STRUCTURE AND GUIDELINES POLICIES AND PROCEDURES December 2012 COMMITMENT TO COMPLIANCE
More informationWhistleblowing Under the False Claims Act
Whistleblowing Under the False Claims Act Session 303, March 9, 2018 Colette G. Matzzie, Partner, Phillips & Cohen LLP Brendan Delaney, Implementation Specialist, Whistleblower 1 Conflict of Interest Colette
More informationCompliance Program. Investigation Policy. Purpose. Applicability. Policy. Unity House of Troy, Inc.
Investigations Policy Purpose To thoroughly respond to and investigate all potential compliance violations of federal, state, and local laws and regulations as well as policies and procedures as they apply
More informationTHE SARBANES-OXLEY ACT OF 2002 AND THE IMPACT ON PUBLIC EMPLOYEE RETIREMENT SYSTEMS
Presentation at State Association of County Retirement Systems SACRS THE SARBANES-OXLEY ACT OF 2002 AND THE IMPACT ON PUBLIC EMPLOYEE RETIREMENT SYSTEMS Presented by Thomas A. Hickey, III Kirkpatrick &
More informationCompleting the Journey through the World of Compliance. Session # COM6, March 5, 2018 Gabriel L. Imperato, Managing Partner Broad and Cassel
Completing the Journey through the World of Compliance Session # COM6, March 5, 2018 Gabriel L. Imperato, Managing Partner Broad and Cassel 1 Conflict of Interest Gabriel L. Imperato, Esq. (Certified in
More informationThe Road Ahead. Diane Meyer Chief Compliance and Privacy Officer Stanford University Medical Center
The Road Ahead Kevin Lyles, Esq. Partner, Jones Day kdlyles@jonesday.com (614) 281-3821 Diane Meyer Chief Compliance and Privacy Officer Stanford University Medical Center DMeyer@stanfordmed.org (650)
More informationAdvisory. Connecticut False Claims Act: A New Arrow in the Quiver of State Regulators
Advisory HEALTH CARE COMPLIANCE PRACTIC E GR OUP I OCTOBE R 2009 A New Arrow in the Quiver of State Regulators On October 5, 2009, Governor Rell signed a civil False Claims Act into law. Connecticut s
More informationTen Questions About Internal Investigations
Ten Questions About Internal Investigations Robert S. Litt Arnold & Porter 202-942-6380 robert_litt@aporter.com 1. When should a company do an internal investigation? 2. What should the goals be? 3. Who
More informationPATRICK S. COFFEY. Chicago, IL office: office:
PATRICK S. COFFEY Partner Milwaukee, WI Chicago, IL office: 312.523.2080 office: 414.978.5538 email: patrick.coffey@ Overview When clients are faced with difficult problems, Pat puts them at ease. He uses
More informationAHLA. A. False Claims Act Primer. Thomas A. Corcoran Assistant US Attorney US Attorney s Office District of Maryland Baltimore, MD
AHLA A. False Claims Act Primer Thomas A. Corcoran Assistant US Attorney US Attorney s Office District of Maryland Baltimore, MD Carol A. Poindexter Norton Rose Fulbright Washington, DC Fraud and Compliance
More informationMATTHEW T. SCHELP. St. Louis, MO office:
MATTHEW T. SCHELP Partner St. Louis, MO office: 314.480.1772 email: matthew.schelp@ Overview A former federal prosecutor, Matt concentrates his practice in the areas of compliance, internal investigations,
More informationTHE RISKS AND EXTRA COSTS OF FEDERAL GOVERNMENT CONTRACTING. Richard J. Bednar Crowell & Moring, LLP (202) ;
THE RISKS AND EXTRA COSTS OF FEDERAL GOVERNMENT CONTRACTING Richard J. Bednar Crowell & Moring, LLP (202) 624-2916; rbednar@crowell.com J. Catherine Kunz Crowell & Moring, LLP (202) 624-2957; ckunz@crowell.com
More informationFCPA Investigations The Pitfalls and the Pendulum. November 10, 2010
FCPA Investigations The Pitfalls and the Pendulum November 10, 2010 Agenda Introduction Presentation Questions and Answers (anonymous) Slides now available on front page of Securities Docket www.securitiesdocket.com
More informationFederal Fraud and Abuse Enforcement in the ASC Space
Federal Fraud and Abuse Enforcement in the ASC Space SCOTT R. GRUBMAN, ESQ. PARTNER CHILIVIS COCHRAN LARKINS & BEVER, LLP (ATLANTA GA) Fraud & Abuse Enforcement Landscape FBI CMS OCR MFCU DCIS DOJ HHS-OIG
More informationMontefiore Medical Center Compliance Program. Welcome House Staff Orientation
Montefiore Medical Center Compliance Program Welcome House Staff Orientation The Healthcare Industry Government is largest payor. Perception that $100 Billion Dollars per year lost because of on healthcare
More informationCharging, Coding and Billing Compliance
GWINNETT HEALTH SYSTEM CORPORATE COMPLIANCE Charging, Coding and Billing Compliance 9510-04-10 Original Date Review Dates Revision Dates 01/2007 05/2009, 09/2012 POLICY Gwinnett Health System, Inc. (GHS),
More informationWhen Navigating the False Claims Minefield, Have an Ethics and Compliance Program on Board
When Navigating the False Claims Minefield, Have an Ethics and Compliance Program on Board Eugene J. Heady Partner Atlanta, Georgia T: 404.582.8055 E: gjheady@smithcurrie.com Worse than traitors in arms
More informationDepartment of Justice Office of Public Affairs press release December 21,
As the primary tool for fighting fraud against US government programs, the civil False Claims Act ( FCA ) has been leveraged effectively by government organizations and relators, or non-government whistleblower
More informationCertifying Employee Training Navicent Health s Corporate Integrity Agreement Year Two
Certifying Employee Training Navicent Health s Corporate Integrity Agreement Year Two Corporate Integrity Agreement Effective 4/23/2015 Term of five years Basic Requirement: Maintain a Compliance Program
More informationConducting Internal Investigations: Staying Ethical in a Cost-Effective World November 7, 2014
10th Annual General Counsel Institute National Association of Women Lawyers Conducting Internal Investigations: Staying Ethical in a Cost-Effective World November 7, 2014 Nancy Saltzman ExlService Holdings,
More informationAPPROACHES FOR HOSPITALS CONFRONTING STARK AND ANTI-KICKBACK ISSUES
APPROACHES FOR HOSPITALS CONFRONTING STARK AND ANTI-KICKBACK ISSUES CORRECTIVE ACTION, PHYSICIAN NEGOTIATION, AND VOLUNTARY DISCLOSURE; CASE STUDIES Dennis Diaz Partner Davis Wright Tremaine LLP Jim Watson
More informationNavigating Self-Disclosure
Navigating Self-Disclosure Charlie Fletcher, CHC Chief Compliance Officer MAURY REGIONAL MEDICAL CENTER Matthew M. Curley BASS BERRY & SIMS PLC John N. Joseph POST & SCHELL, P.C. Self-Disclosure: Legal
More informationState False Claims Acts
State False Claims Acts How States Can Recover Stolen Money Jim Moorman, TAF Roderick Chen, OIG-HHS The Scope of the Fraud No one knows for sure how much fraud infects Medicaid and Medicare. The U.S. Government
More information