BC Advantage - 2016 Issue 11
DOJ’s Commitment to Holding Executives Accountable for Healthcare Fraud
Last year, the Department of Justice (DOJ) released a policy memorandum, titled "Individual Accountability for Corporate Wrongdoing," also known as the "Yates Memo." The DOJ shifted its approach to fighting corporate fraud and misconduct by focusing its investigative efforts on those individuals within a corporation who perpetrated wrongdoing. The policy guidelines were discussed in this earlier post.Providers undergoing investigations for violations under the False Claims Act, Stark Law, and/or Anti-Kick Back Law, will have increased pressure from the DOJ to present evidence of individual wrongdoing. Tuomey Healthcare System (now part of Palmetto Health in Columbia, SC)...
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