Disclose Smart: Strategic Considerations in Making a Government Disclosure

By on March 13, 2015

A former deputy chief in the U.S. Department of Health and Human Services’ Office of Counsel to the Inspector General weighs in on the growing need for self-disclosure by health industry entities

After years of significant federal government attention to health care fraud, some prosecutors are starting to wonder whether the industry has indeed embraced a new culture of compliance. Just last month, Zane David Memeger, the U.S. Attorney for the Eastern District of Pennsylvania in Philadelphia, put it directly when he said, “the expectation is that you will have a strong compliance program”[1] now as a result of the large number of False Claims Act (FCA) cases and settlements over the past 20 years. “But at the end of the day, I suspect that at some point, entities may push the envelope again.”

Read the full article from AHLA Weekly.

Tony Maida
Tony Maida counsels health care and life sciences clients on government investigations, regulatory compliance and compliance program development. Having served as a government official, Tony has extensive experience in health care fraud and abuse and compliance issues, including the federal and state Anti-Kickback and Stark Laws and Medicare and Medicaid coverage and payment rules. He represents clients in False Claims Act (FCA) qui tam matters, government audits, civil monetary penalty and exclusion investigations, and Centers for Medicare and Medicaid Services (CMS) suspension, and revocation actions, negotiating and implementing corporate integrity agreements, and making government self-disclosures. Read Tony Maida's full bio.