The DOJ is Set to Increase Criminal Enforcement

The United States Attorney General recently discussed the 2022 priorities of the Department of Justice (DOJ).  In his remarks he indicated the DOJ will be aggressively prosecuting corporate entities as well as individuals for fraud, corruption, bribery, and anticompetitive arrangements.  He further stated the DOJ’s top priority is is to prosecute individuals who commit and profit from corporate wrong doing.

In order to achieve their goals, the DOJ is seeking to add over $325 million for white-collar crime enforcement with an additional $36.5 million earmarked for pandemic fraud enforcement.

With respect to healthcare specifically, the AG outlined a three-tired approach to tackling fraud and abuse: Increased collaboration and joint task forces with the Office of Inspector General (OIG)  and the Centers for Medicare and Medicaid Services (CMS) as well as other local, state and federal entities to identify health care fraud. Addition of a new group of embedded FBI agents. Large expansion of data analytics to identify anomalies suggestive of fraud. The DOJ has issued guidance on their evaluation of corporate compliance programs in the context of prosecutions.  The DOJ also considers a number of factors in enforcement settlements including the individuals involved in the wrong doing and any prior history of non-compliance.

The time to take a critical look at the effectiveness of your compliance program is now.  Objectively review your program through the lens of the DOJ and their approach to evaluating corporate compliance.  Identify areas of weakness and implement necessary revisions. 

The HBE team serves as an independent, objective review organization.  We routinely conduct risk assessments and systems reviews.  We have the experience and expertise to assist you with the evaluation of your corporate compliance program as well as any necessary corrective action. 

We have provided the links to additional information and guidance.
DOJ Evaluation of Corporate Compliance:

DOJ Corporate Crimes Enforcement Policy:

AG’s remarks:
HBE’s team of experts is also available to assist you with routine auditing and monitoring, policy and procedure development as well as customized education and training for your clinical and administrative staff.

DISCLAIMER:  This newsletter contains only summary information and highlights; it should be read in conjunction with the full article or document provided as a link.  Any advice or recommendations are general and specific questions should be directed to professional counsel.


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