Paul M. Thompson Paul M. Thompson

Subscribe to Paul M. Thompson's Posts
Paul 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 , , , and 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....

Continue Reading



Healthcare Enforcement Quarterly Roundup – Q2 2019


By , , , , , , , , , , , , , and 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,...

Continue Reading



DOJ Guidance on Evaluation of Corporate Compliance Programs: Key Takeaways


By , , , , and 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...

Continue Reading



Health Care Enforcement Quarterly Roundup – Q1 2019


By , , , , , , , , , , , , and 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...

Continue Reading



Health Care Enforcement Quarterly Roundup | Q4 2018


By , , , , , , , , , , and 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...

Continue Reading



Health Care Enforcement Quarterly Roundup | Q3 | September 2018


By , , , , , , , , , , , and 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...

Continue Reading



Health Care Enforcement Quarterly Roundup | Q2 | July 2018


By , , , , , , , , , , , , and 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...

Continue Reading



Register today! Health Care Enforcement Q2 Roundup Webinar


By , , and 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...

Continue Reading



New DOJ Task Force to Take on Opioid Crisis Using the FCA and Other Enforcement Tools


By , and 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,...

Continue Reading



When Relators Steal Corporate Documents: Northern District of Illinois Dismisses Counterclaim for Breach of Contract


By 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...

Continue Reading



BLOG EDITORS

STAY CONNECTED

TOPICS

ARCHIVES