DOJ TARGETS COVID RELATED FRAUD

On March 10, 2022, the Department of Justice (“DOJ”) appointed a Director for COVID-19 Fraud Enforcement.[1] As a part of this announcement, DOJ announced some of its priorities in Health Care Fraud enforcement. The priorities focus on kickbacks, utilizing the relaxed rules to bill for medically unnecessary or never performed services, vaccine-related fraud, and fraud …

Between Absolute and Amorphous: The Draft Guidelines on Vertical Mergers: Commentary on the Draft 2020 Guidelines

Businesses at different levels in the supply chain of a product choose to merge (“vertical mergers,” compared with “horizontal mergers” where business at the same level in the supply chain merge) for a variety of reasons, many of which can be beneficial to competition and/or consumers. Vertical mergers can lead to efficiencies in supply chains, …

A Review of Key 2018 False Claims Act Recoveries and Developments

A summary of the article “A Review of Key 2018 False Claims Act Recoveries and Developments,” which first appeared in Physicians Practice. In December, the Department of Justice announced that it recovered more than $2.8 billion in False Claims Act judgments and settlements for fiscal year 2018. The largest settlements involved pharmaceutical companies: AmerisourceBergen Corporation, …