Supreme Court Weighs in on Implied False Certification Theory

Ryan Meade Editor-in-Chief Director of Regulatory Compliance Studies at Loyola University Chicago School of Law   The Supreme Court’s decision yesterday in  Universal Health Services, Inc. v. U.S. ex rel Escobar (“UHS”) has had some strange initial summaries suggesting this is a gloom and doom opinion for actors who submit claims to the United States.  I …
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A New Role for Compliance Programs in HHS-OIG Resolutions of Non-compliant Conduct

Ryan Meade Editor-in-Chief Director of Regulatory Compliance Studies at Loyola University Chicago School of Law   A recent commentary from the U.S. Department of Health & Human Services’ Office of Inspector General (HHS-OIG) indicates it will not consider the existence of an effective compliance program as a positive factor in resolving civil non-compliance but it …
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Reasons for an Athletics Compliance Department

Gilbert Carrillo Executive Editor Loyola University Chicago School of Law,  JD 2017   The National Collegiate Athletic Association (“NCAA”) is a non-profit organization that regulates athletes in over 1,200 institutions, associations and conferences.  The NCAA also organizes many of the athletic programs of its member schools.  The amount of members in the NCAA requires rules …
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Elemental: Internal or External Hotlines?

Ryan Meade Editor-in-Chief Director of Regulatory Compliance Studies at Loyola University Chicago School of Law   Yesterday I gave a webinar on compliance program hotlines and an interesting question came in after the broadcast: “Internally staffed compliance hotlines seem like a bad idea.  Doesn’t an internal hotline increase the company’s regulatory risk?”  Internal hotlines could increase …
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On this Day: the Federal Register (April)

Ryan Meade Editor-in-Chief Director of Regulatory Compliance Studies at Loyola University Chicago School of Law   The number of annually published pages of the Federal Register doesn’t tell us much about the growth of regulations in the United States. After all, even repeals of regulations take up page counts.  But the size of the Federal …
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Adding Federal Grant Compliance to the Audit Plan: the University of Florida Case

Greg Grabinski Executive Editor Loyola University Chicago School of Law, JD 2016   One of the best sources for designing a compliance program’s annual audit plan is to look around to see what is happening at peer institutions.  If there is a regulatory settlement in a peer organization’s similar business line, then the subject-matter should …
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Lessons Still to be Learned from Settlements of Implantable Cardiac Device Cases

Gail Jankowski Executive Editor Loyola University Chicago School of Law, JD 2016   Although the DOJ reached 70 settlements involving 457 hospitals in 43 states for more than $250 million related to cardiac devices that were implanted in Medicare patients which violated coverage requirements, they were not done yet. Another batch of 51 hospitals settled …
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