>Just sit and start at 2:33
>See the pyramids?
>Now turn up the volume and listen to the crowd when they appear.
Noticed the crowd got really loud at :15 with the Statue of Liberty.
>Just sit and start at 2:33
>See the pyramids?
>Now turn up the volume and listen to the crowd when they appear.
Noticed the crowd got really loud at :15 with the Statue of Liberty.
Interesting article about the Whistleblower Act in terms of
THE PERFECT STORM
''The book, The Perfect Storm, by
Sebastian Junger, describes in graphic
detail the havoc created when three
smaller storms gather and combine into
one. "
THREE METAPHORICAL 'STORMS' HAVE NOW COMBINED
'''1. TARP and stimulus funds have
the government on track to spend trillions of dollars'''
Any entity that either
directly or indirectly receives federal
funds, including healthcare providers
that participate in federal programs
such as Medicaid and Medicare, are at
risk. These entities, including contractors, subcontractors, and vendors, are
also likely to face whistleblower retaliation claims from employees, former
employees, and competitors.
'''2. The second storm has arisen from
FERA’s recent amendments to the FCA.'''
A. First,
Congress removed the requirement that
the allegedly false claim actually be
presented to the government for payment.
Now liability may attach to claims that
are submitted to a “contractor, grantee,
or other recipient” of federal funds,
regardless of whether a false claim was
submitted to the government.
B. there
is no longer a requirement that an individual or entity act with the specific
intent to defraud the government.
Together, these two amendments expose
a large number of companies to potential
liability under the FCA, including
companies that are not traditionally
thought of as – and have never considered themselves to be – government
contractors, such as subcontractors and
vendors who simply work with grantees
or recipients of federal funds.
3. Ignorance
A recent study found that nearly
80 percent of business executives from a
broad array of companies, including
those in the healthcare industry, were
A GATHERING STORM: THE NEW FALSE CLAIMS
ACT AMENDMENTS AND THEIR IMPACT ON
HEALTHCARE FRAUD ENFORCEMENT
15 Volume 21, Number 6, August 2009 The Health Lawyer
unfamiliar with the FCA.6 This means
that many companies, which are now
unwittingly in the cross-hairs of federal
fraud enforcement, are likely unprepared
to prevent FCA violations through the
implementation and execution of
adequate compliance measures.
sauce:
https://www.crowell.com/documents/New-False-Claims-Act-Amendments-And-Their-Impact-On-Health-Care-Fraud-Enforcement.pdf