Paul M. Thompson
Subscribe to Paul M. Thompson's PostsPaul M. Thompson focuses his practice on white-collar criminal defense, congressional investigations and appellate matters. He is a current member of the Firm-wide Management Committee and a former member of the Firm’s Executive Committee. From 2011 to 2015, Paul served as partner-in-charge of the Washington, DC office. Read Paul M. Thompson's full bio.
New Guidance on Medicare Payment Rule Enforcement
By Emily J. Cook, Michael B. Kimberly, Monica Wallace, Paul M. Thompson and Tony Maida on Dec 5, 2019
Posted In Other Notable Enforcement Actions
A few days before Thanksgiving, the news media published an internal memo by the Office of General Counsel (OGC) at the US Department of Health and Human Services (Department) to officials at the Centers for Medicare and Medicaid Services (CMS). The memo expressed OGC’s views on the impact of the Supreme Court’s Azar v. Allina Health Services, et. al., No....
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Healthcare Enforcement Quarterly Roundup – Q2 2019
By Amandeep S. Sidhu, David Quinn Gacioch, Drew Elizabeth McCormick, Edward G. Zacharias, Irene A. Firippis, Jennifer Aronoff, Jennifer B. Routh, Katrina Rogachevsky, Lauren Evans, Laura McLane, Marshall E. Jackson, Jr., Paul M. Thompson, Sophia A. Luby, Theodore Alexander and Tony Maida on Aug 27, 2019
Posted In Additional Compliance Resources, Compliance Developments, Other Notable Enforcement Actions, Pharmaceuticals
In this second installment of the Healthcare Enforcement Quarterly Roundup for 2019, we cover several topics that have persisted over the past few years and identify new issues that will shape the scope of enforcement efforts for the remainder of this year and beyond. In this Quarterly Roundup, we discuss DOJ’s guidance on compliance programs and cooperation credit,...
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DOJ Guidance on Evaluation of Corporate Compliance Programs: Key Takeaways
By McDermott Will & Emery, Michael W. Peregrine, Michael S. Stanek, Paul M. Thompson, Sarah E. Walters and Tony Maida on May 9, 2019
Posted In Compliance Developments, Government investigation
Boards and management should make use of recent expanded guidance from the US Department of Justice to ensure that their compliance programs are considered “effective” if and when an investigation arises. Companies should affirmatively answer three fundamental questions in evaluating a compliance program: Is the compliance program well designed? Is the program being implemented effectively...
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Health Care Enforcement Quarterly Roundup – Q1 2019
By McDermott Will & Emery, Amandeep S. Sidhu, Drew Elizabeth McCormick, Irene A. Firippis, James A. Cannatti III, Jennifer B. Routh, Laura McLane, Matthew M. Girgenti, Paul M. Thompson, Sean Hennessy, Sophia A. Luby, Theodore Alexander, Tony Maida and T. Reed Stephens on Apr 26, 2019
Posted In Additional Compliance Resources, Other Notable Enforcement Actions, Pharmaceuticals
In this first installment of the Health Care Enforcement Quarterly Roundup for 2019, we continue to monitor trends we identified in 2018 and introduce new enforcement efforts that are expected to persist in the coming year. In this Roundup, we focus on increased enforcement activity against electronic health record (EHR) companies, enforcement against individuals (with an acute focus...
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Health Care Enforcement Quarterly Roundup | Q4 2018
By McDermott Will & Emery, Amandeep S. Sidhu, Irene A. Firippis, Jennifer B. Routh, Laura McLane, Matthew M. Girgenti, Natalie Colvin, Paul M. Thompson, Sophia A. Luby, Theodore Alexander, Tony Maida and T. Reed Stephens on Jan 30, 2019
Posted In Compliance Developments, Other Notable Enforcement Actions, Yates Memorandum
This latest installment of the Health Care Enforcement Quarterly Roundup reflects on trends that persisted in 2018 and those emerging trends that will carry us into 2019 and beyond. Leading off with the US Department of Justice’s (DOJ) December announcement of its fiscal year 2018 False Claims Act (FCA) recoveries, it remains clear that the...
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Health Care Enforcement Quarterly Roundup | Q3 | September 2018
By Paul M. Thompson, Sophia A. Luby, Theodore Alexander, Tony Maida, T. Reed Stephens, McDermott Will & Emery, Amy H. Kearbey, Amandeep S. Sidhu, Irene A. Firippis, Jennifer B. Routh, Laura McLane, Matthew M. Girgenti and Natalie Colvin on Oct 8, 2018
Posted In Compliance Developments, Other Notable Enforcement Actions
In the latest installment of Health Care Enforcement Quarterly Roundup, we examine key enforcement trends in the health care industry that we have observed over the past few months. In this issue, we report on: Practical applications of recent guidance from the US Department of Justice (DOJ) A recent blow to DOJ’s effort to use...
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Health Care Enforcement Quarterly Roundup | Q2 | July 2018
By McDermott Will & Emery, Amandeep S. Sidhu, David S. Rosenbloom, Emily J. Cook, Laura McLane, Matthew M. Girgenti, Monica Wallace, Natalie Colvin, Paul M. Thompson, Sandra M. DiVarco, Stephen W. Bernstein, Sophia A. Luby, Tony Maida and T. Reed Stephens on Jul 18, 2018
Posted In Compliance Developments, Other Notable Enforcement Actions
How will key trends and developments in health care policy and enforcement impact future litigants? In the latest Health Care Enforcement Quarterly Roundup, we address this question in the context of: Continued interpretations of the landmark Escobar case The latest guidance from US Department of Justice (DOJ) leadership regarding enforcement priorities The uptick in state...
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Register today! Health Care Enforcement Q2 Roundup Webinar
By Amandeep S. Sidhu, Laura McLane, Paul M. Thompson and Tony Maida on Jul 2, 2018
Posted In Compliance Developments, Government investigation, Other Notable Enforcement Actions, Public Disclosure Bar
Health Care Enforcement Q2 Roundup Webinar Date: Tuesday, July 17, 2018 Time: 11:00 am PDT | 12:00 pm MDT | 1:00 pm CDT | 2:00 pm EDT REGISTER NOW How will recent developments and emerging trends related to health care fraud and abuse impact future investigation targets and litigants? Our upcoming Health Care Enforcement Quarterly...
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New DOJ Task Force to Take on Opioid Crisis Using the FCA and Other Enforcement Tools
By Amandeep S. Sidhu, Matthew M. Girgenti and Paul M. Thompson on Mar 2, 2018
Posted In Additional Compliance Resources, Compliance Developments, Government investigation, Other Notable Enforcement Actions, Pharmaceuticals
Earlier this week, the US Department of Justice (DOJ) launched a new front in its effort to combat the opioid crisis and explicitly stated that it will deploy the False Claims Act (FCA) as part of its offensive. In a press release and parallel speech delivered by Attorney General Jeff Sessions on February 28, 2018,...
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When Relators Steal Corporate Documents: Northern District of Illinois Dismisses Counterclaim for Breach of Contract
By Paul M. Thompson on May 18, 2016
Posted In Retaliation
The issue is one that various courts have addressed over the years: what recourse does a corporation have when a relator steals confidential information and discloses it to his or her attorney and to the government? The answer is . . . it depends. It depends on the scope of the materials taken, their relationship...
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