In the MA space, historical enforcement actions taken by both OIG, under their administrative authorities, and DOJ, under the False Claims Act (“FCA”), have related to alleged MA risk adjustment payment inflation schemes. See, e.g., DaVita, Sutter Health, Beaver Medical, Martin’s Point,...
The Department of Justice’s (“DOJ”) Justice Manual defines a target as “a person as to whom the prosecutor or the grand jury has substantial evidence linking him or her to the commission of a crime and who, in the judgment of the prosecutor, is a putative defendant.”[1]If you ar...
See, e.g., my discussion in HealthCare Fraud Prosecutorial Trends in 2024: Predictions Based Upon Latest OIG DOJ Enforcement Report. Finally, in conclusion to the answer of why I represent clients in the federal criminal justice system, I point to the Standard 4-1.2 of the Defense Function ...
This theory finds further support in the fact that the United States Department of Justice (DOJ) has actually indicted six individual members of the GRU for various crimes, in part based on their involvement in the creation and dissemination of NotPetya (U.S. Indictment).82 The U.S. Indictme...
” without consideration of a company’s financial circumstances. Although federal criminal statutes and the U.S. Sentencing Guidelines Manual have allowed consideration of a company’s financial circumstances in assessing a fine or penalty, the new guidance clarifies the framework the DOJ will rely ...
19. Saabira Chaudhuri & Ben DiPietro, Parker Drilling to Take Charge for SEC, DOJ Settlement, WALL ST. J. CORRUPTION CURRENTS (Feb. 15, 2013, 5:18 PM), http://blogs.wsj.com/corruption- currents/2013/02/15/parker-drilling-to-take-charge-for-sec-doj-settlement/. 20. Siemens (Germany...