Category Archives: Government Investigations

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Potential Risks of Healthcare Joint Ventures Between Insurance Companies and Hospitals

Healthcare joint ventures are nothing new.  Since the mid-2000’s, physician-hospital ventures have been resurgent, notwithstanding the Office of Inspector General’s skepticism regarding the risk of fraud and abuse when investors are sources of referrals and the filing of numerous whistleblower actions under the False Claims Act (e.g., the nine cases filed against Health Management Associates, … Continue Reading

Pfizer FCPA Settlement Emphasizes the Importance of Robust Compliance Programs for the Healthcare Industry

The healthcare industry has been under increased SEC and DOJ scrutiny lately for potential FCPA violations. What has been described as an “industry sweep,” has focused primarily on medical device and pharmaceutical companies. These companies are particularly vulnerable to FCPA violations because the DOJ and the SEC have taken the stance that employees of state-owned … Continue Reading

California AG Becomes the Latest Antitrust Enforcer to Investigate Hospital/Doctor Group Combinations

By David R. Garcia California’s Attorney General has recently launched a broad investigation into whether increasing consolidation among hospitals and physician groups may be resulting in supra-competitive prices for medical care, according to several media sources. This investigation reflects increased scrutiny by antitrust regulators on a nationwide basis of rapid consolidation among the healthcare industry, … Continue Reading

Managing an Internal Audit

By Karie Rego Internal investigations of billing issues usually involve audits. It is important to approach an audit carefully or the auditors can create more risk for the organization by misinterpreting the standards. Thus, it is very important to know what you are auditing before you audit. It seems simple but this is often overlooked. … Continue Reading