It’s a lesson that bears repeating – you can’t find what you don’t look for. To know what to look for and thereby achieve peak performance and tackle key risks, compliance programs must identify and incorporate the trends in government enforcement. To help identify those trends, we recommend reviewing the enforcement priorities announced by the government in 2021, recently announced resolutions, and significant advisory opinions from the Office of the Inspector General.
The change in the presidential administration brought renewed energy to the Department of Justice’s (“DOJ”) health care fraud enforcement programs and will likely bring additional and more sophisticated resources to the government’s enforcement activities. While fraud and abuse cases can be in the investigative pipeline for years before coming into the public eye, certain trends can be detected from public and other pronouncements from the DOJ over the past year. We highlight those notable trends so that they can inform your compliance program.
The Yates Memo is Back. In a policy shift that had significant impact on enforcement in health care, former Deputy Attorney General Sally Yates issued a memo in 2015 that required corporations seeking cooperation credit in fraud investigations to disclose relevant facts about the individuals that were involved in the misconduct. This memo reflected a growing practice of the DOJ, including in the context of False Claims Act investigations, to not be...
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