In Landmark Decision, Second Circuit Reverses Conviction For Off-Label Promotion
On December 3, 2012, in United States v. Caronia, a three-judge panel of the Second Circuit reversed a drug salesperson’s conviction for conspiracy to introduce a misbranded drug into interstate...
View ArticleHHS OIG Takes Aim At CMS’ Oversight Of Electronic Health Records Incentive...
On November 29, 2012, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) issued a report raising concerns about the Centers for Medicare and Medicaid Services’...
View ArticleCMS Issues Final Physician Payment Sunshine Act Regulations
On February 1, 2013, the Centers for Medicare and Medicaid Services (CMS) published the long-awaited final regulations implementing the Physician Payment Sunshine Act (Act or Sunshine Act). The...
View ArticleGetting Ready For The Physician Payment ‘Sunshine’ Rule
Originally Published in BNA Bloomberg, Medical Devices Law & Industry Report on March 20, 2013. On February 1, 2013, the Centers for Medicare and Medicaid Services (CMS) published the long-awaited...
View ArticleWeighing The Price Of Crime — Apportioning Restitution Based On Relative Fault
Criminal justice practitioners understand that ‘‘joint and several liability’’ stands for the common proposition that each co-conspirator should be equally responsible for all provable losses the...
View ArticleOregon Settlement Expands Disclosure Obligations Of Physicians Receiving...
As of August 1, 2013, pharmaceutical companies and medical device manufacturers are required to report to the federal government payments made to physicians under the Physician Payment Sunshine Act...
View ArticleD.C. Circuit Vacates Barko Ruling on Scope of Privilege in Internal...
On June 27, 2014, the D.C. Circuit vacated the U.S. District Court for the District of Columbia’s hotly-debated opinion in United States ex rel. Barko v. Halliburton Co., making it clear that internal...
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