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DOJ Issues First Healthcare Declination Under Revised Corporate Enforcement Policy: Key Takeaways for Healthcare Companies and MSOs

By Andrea Linna, Nawa Lodin & Seamus Taylor on August 17, 2026
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The Department of Justice (DOJ) has issued its first healthcare-related corporate declination under its revised Corporate Enforcement and Voluntary Self-Disclosure Policy, declining to prosecute a management services organization (MSO) while simultaneously indicting the former CEO and founder of the underlying optometry practice on healthcare fraud and Anti-Kickback Statute charges.

The alert provides background on the matter, examines the declination’s significance for the MSO-professional corporation (MSO-PC) model, and highlights the value of a robust healthcare compliance program.

Read the full alert.

Photo of Andrea Linna Andrea Linna

Andrea is a partner and member of the digital health industry group and healthcare practice. With more than 15 years dedicated to healthcare law, she represents digital health and health tech clients on regulatory matters throughout the business life cycle, including care delivery…

Andrea is a partner and member of the digital health industry group and healthcare practice. With more than 15 years dedicated to healthcare law, she represents digital health and health tech clients on regulatory matters throughout the business life cycle, including care delivery structures, reimbursement, telehealth, healthcare transactions, and compliance with federal and state healthcare laws.

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Photo of Nawa Lodin Nawa Lodin

Nawa is a Chambers USA-ranked associate whose practice focuses on healthcare regulatory and transactional matters. She advises healthcare, digital health, life sciences, and technology companies on artificial intelligence and machine learning, telehealth, fraud and abuse laws, and complex healthcare transactions, including evolving state…

Nawa is a Chambers USA-ranked associate whose practice focuses on healthcare regulatory and transactional matters. She advises healthcare, digital health, life sciences, and technology companies on artificial intelligence and machine learning, telehealth, fraud and abuse laws, and complex healthcare transactions, including evolving state healthcare transaction review and notification requirements.

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Photo of Seamus Taylor Seamus Taylor

Seamus is an associate and member of the digital health industry group and healthcare practice. He advises companies on healthcare regulatory matters including corporate practice of medicine, fraud and abuse laws, HIPAA, Medicare and Medicaid, and state licensing requirements. He also counsels clients…

Seamus is an associate and member of the digital health industry group and healthcare practice. He advises companies on healthcare regulatory matters including corporate practice of medicine, fraud and abuse laws, HIPAA, Medicare and Medicaid, and state licensing requirements. He also counsels clients on healthcare transactions, contractual arrangements, entity formation, governance, and compliance programs.

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  • Posted in:
    Corporate Governance and Compliance, Health Care and Life Sciences
  • Blog:
    The Consult
  • Organization:
    Wilson Sonsini Goodrich & Rosati
  • Article: View Original Source

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