By: Gabriel Imperato
The Department of Justice (DOJ) has recently articulated important enforcement policies and created the position of Compliance Counsel, which are expected to have a dramatic impact on criminal and civil prosecution of healthcare fraud matters. The policy pronouncements are related to the systematic review of civil qui tam complaints for potential criminal culpability and also review for individual liability for organizational healthcare fraud.
The goal is to raise the stakes and consequences for misconduct with a more direct deterrent effect. The compliance counsel is also expected to hold organizations more directly accountable for the effectiveness of their compliance programs. The following article will discuss these recent developments and the expected impact on enforcement and compliance in the healthcare industry.
Please visit this page to see the article as it appeared in Compliance Today, a publication of the Health Care Compliance Association (HCCA).