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CMS Issues Proposed Rules on Reporting and Returning of Overpayments Under...

The Centers for Medicare and Medicaid Services (CMS) recently issued its Proposed Rules for implementing provisions of the Patient Protection and Affordable Care Act (Act) on reporting and returning...

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Building Credibility with the Government During an Investigation

Catherine Dunn recently detailed several ways to build credibility with the Government during FCPA investigations, in the May 25, 2012 issue of Corporate Counsel, an online newsletter.  It’s a useful...

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Not Free, But the Freeh Investigative Report Shows Its Value

Last week’s release of the investigative report of the Penn State – Jerry Sandusky scandal has brought into clear focus the value of independent investigations, a topic my partner Dan Purdom addressed...

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Pfizer Joins the List of Recent Large FCPA Settlements

Yesterday the U.S. Attorney’s office filed an Information and deferred prosecution agreement against Pfizer H.C.P. Corp., a subsidiary of Pfizer Inc.  The deferred prosecution agreement is the result...

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The Hard Choice: To Hunker Down or Not

Every person or organization accused of wrongdoing is faced with a hard choice: (1) hunker down, hope it goes away, and if it doesn’t, deny and make them prove guilt; or (2) investigate the allegation...

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The Privatization of Prosecution

As the election campaigns mercifully grind to a close before resuming in, say, six months, I reflect on a topic that we’ve heard much about: the “role of government.” All this has made me consider the...

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FY 2013 Federal Health Care Fraud Enforcement Priorities

My learned colleague, Lee Smith, focused on the increasing privatization of prosecutorial behavior in his recent post to this blog. Companies in highly regulated industries are well-versed in the...

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White Collar – Corporate Settlements Continue to Grow, But Do They Produce...

Deferred and nondeferred prosecution agreements with the federal government hit an all-time record in 2012 — approximately $9 billion. This was a 50 percent increase over the previous record year —...

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