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The Evolving Role of Compliance in Healthcare Fraud Investigations

21 April 2017

The Department of Justice Criminal Fraud Section recently released the "Evaluation of Corporate Compliance Programs" guidance document. This publication emphasizes that compliance and remediation efforts are scrutinized by prosecutors at all stages of an investigation. With the backdrop of the healthcare and life sciences industries, this program discussed current enforcement priorities of relevant agencies and examined how this new compliance guidance aligns with traditional guidance to inform compliance program priorities and resource allocation.

Presenter Tom Beimers carefully examined ethical considerations imposed by the DOJ guidance, as well as predicate ethical practices guidance documents issued by the Department of Health & Human Services and industry trade associations. In this program, he provided historical context for this review of ethical practices rules by describing the evolution of compliance programs in these industries. Attendees gained valuable insight into how an entity's ethical culture can become an aggravating or mitigating factor in DOJ charging decisions and the effect a strong compliance program can have on post-resolution oversight requirements.

From Hogan Lovells

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