Over the past several years, the federal government has collected billions in fines and restitution from corporations accused of violating federal health care statutes and regulations. The targets of the government actions were not small, unknown companies, but major U.S. corporations including Eli Lilly, Pfizer and Abbott Laboratories. In addition to the staggering financial payments to the government, these corporations also incurred significant defense costs and unavoidable disruption of their businesses.
Considering these significant past actions, the newly enacted Fraud Enforcement and Recovery Act (FERA) and the growing “saber rattling” by the Department of Justice (DOJ) and the Department of Health and Human Services (HHS), the question arises: Can proactive internal investigative and compliance measures make a difference?
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