Thomas Beimers

Nov 16, 2023 | jdsupra.com | Eliza Andonova |Thomas Beimers |Mike Dohmann

The GCPG’s content is a high-level amalgamation of OIG’s existing guidance that may be particularly useful for entities and individuals who are less experienced analyzing health care compliance issues. To that end, the GCPG is written in a corporate compliance manual-style format, enriched with graphics and practical tips that make it a helpful guide for standing up a compliance program.

Jun 7, 2023 | jdsupra.com | Thomas Beimers |Jonathan Diesenhaus |Jessica Ellsworth

The Court granted cert in U.S. ex rel. Schutte v. SuperValu, Inc. and U.S. ex rel. Proctor v. Safeway, Inc 1 to offer guidance on the scope of the False Claims Act’s scienter requirement: what does it mean for a claimant to “knowingly” present a false or fraudulent claim to the U.S. government in the context of a complex, ambiguous regulatory scheme?

May 26, 2023 | jdsupra.com | Thomas Beimers |Melissa Bianchi |Mahmud Brifkani

Suspension of NDRA for late reporting. CMS proposes a process for suspension (as opposed to termination) of a manufacturer’s Medicaid rebate agreement for failure to timely report drug pricing or drug product information. If a manufacturer fails to timely report such information, CMS would provide written notice to the manufacturer of the noncompliance and the manufacturer would have 90 days after such notice to provide all required information.

Mar 31, 2023 | lexology.com | Jonathan Diesenhaus |Thomas Beimers |Jessica Ellsworth |Eliza Andonova |Laura Hunter |Mike Dohmann | +2 more

The Sixth Circuit expanded the existing circuit split regarding when a kickback causes a federal health care claim to be false or fraudulent under the False Claims Act (FCA) and set out a new analysis for what constitutes impermissible remuneration under the federal Anti-Kickback Statute (AKS), curbing the scope of potential liability. On Tuesday, the Sixth Circuit released its opinion in U.S. ex rel. Shannon Martin, et al. v.