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.”