DOJ and GSK Enter Into Record-Setting $3 Billion Settlement, Expansive CIA

The Department of Justice today announced the largest-ever health care fraud settlement and largest-ever payment by a drug company.  Global pharmaceutical giant GlaxoSmithKline LLC (GSK) agreed to pay $3 billion to resolve criminal and civil liability in connection with its drug sale and promotion practices, …

[Read more...]

The ZPICs are Here! Is Your Organization Ready?

Effective April 24th, 2012, Cahaba Safeguard Administrators, LLC, the Zone Program Integrity Contractor (ZPIC) for Zone 3, is fully operational.  Zone 3 includes the following states: Minnesota, Indiana, Michigan, Illinois, Ohio, Wisconsin and Kentucky.  Implementation of a ZPIC contractor in Zone 3 was delayed …

[Read more...]

District Court Decisions Help Refine Heightened Pleading Standard For False Claims Act Cases

Two decisions were issued this past week in a district that handles a large number of qui tam actions.  The United States District Court in Boston issued decisions that will help demarcate the point where conduct is too attenuated from the submission of a claim to form a potential basis for False Claims Act …

[Read more...]

Caught by the CIA: Corporate Integrity Agreement Violation is Grounds for False Claims Act Liability

In a decision with potentially significant implications, the U.S. Court of Appeals for the Eleventh Circuit ruled on February 22, 2012, that the failure to satisfy reporting and monitoring obligations under a Corporate Integrity Agreement can form the basis for False Claims Act (FCA) liability. A Novel …

[Read more...]

Top 10 Lessons From The Bradford Regional Case

If you have not done so already, you should read the court’s opinion in United States ex rel. Singh v. Bradford Regional Medical Center, No. 04-186 (W.D. Pa. Nov. 10, 2010). The case examined an arrangement between Bradford Regional Medical Center (Hospital) and Drs. Vaccaro and Saleh and their practice entity …

[Read more...]

Physician Fraud and Abuse Guidelines: Starting Young

According to an Office of Inspector General (OIG) study, less than half of all U.S. medical schools provide training on Medicare and Medicaid fraud and abuse laws. Further, the OIG study found that only two-thirds of residency and fellowship programs reported providing their residents or fellows with any …

[Read more...]