Coronavirus Checklist for Nursing Homes and Hospitals

Comprehensive Guide to Hospital Readiness and Infection Control Introduction The ongoing threat of coronavirus (COVID-19) requires hospitals to maintain rigorous preparedness and response plans. This detailed checklist is designed to help hospital administrators and healthcare teams ensure readin...

DOJs New Evaluation of Corporate Compliance Programs – The Essence of Compliance

The Criminal Division of the United States Department of Justice (DOJ) revised its Evaluation of Corporate Compliance Programs in April 2019. Initially introduced in 2017, this document provides prosecutors with structured guidance for investigations, charging decisions, and plea negotiations. Th...

Can an ACO Violate the Antitrust Laws?

This may not be obvious to people who do not keep track of the Federal Trade Commission (FTC)/Department of Justice antitrust enforcement policy, but an enforcement action has never been published involving an Accountable Care Organization (ACO) that participates in Managed Security Service Provi...
Complying with Michigan’s New Controlled Substance Laws – The Bona-Fide Prescriber-Patient Relationship Requirement The state of Michigan has enacted a number of separate pieces of legislation to address the opioid epidemic.  Most of these laws are directed at controlling the prescribing rel...

Treatment Center Pleads Guilty to Anti-kickback Statute Violations Involving Alcohol and Drug Addiction Treatment Centers

The Department of Justice (DOJ) recently announced the guilty plea of two individual alcohol and substance abuse treatment center owners for their participation in what the DOJ labeled a “multi-million dollar health care fraud and money laundering scheme.”  The two individuals owned a licens...