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Government Investigations, Audits + Self-Disclosures in Health Care

Health care entities face unique risks and challenges due to the ever-increasing government regulation and enforcement of state and federal fraud and abuse laws. The attorneys in Robinson+Cole’s Health Care Government Investigations, Audits + Self-Disclosures group integrate their in-depth substantive health care knowledge with their experience in conducting internal investigations and representing clients before state and federal authorities.

Recent experience includes representing clients in connection with investigations by state attorneys general and other state agencies as well as the U.S. Department of Justice, the U.S. Department of Health and Human Services Office of Inspector General, and the Centers for Medicare & Medicaid Services. These investigations related to alleged violations of state and federal anti-kickback laws, the federal Stark Law, and the federal False Claims Act. Our team has assisted hospitals, health systems, and other health care providers with engaging in internal compliance investigations, developing compliance programs, conducting compliance education and training, and implementing reporting protocols.

Experience


Advise + Represent Clients in CT DSS Proceedings

Regularly advise and represent clients in proceedings before the Connecticut Department of Social Services regarding financial audits, administrative sanctions and Title XIX appeals.

Investigation of Billing Practices

Representation of hospital network and behavioral health center in an investigation of billing practices brought by the FBI and Office of the Inspect General.

Corporate Compliance Plans

Regular representation of hospitals, community providers and physician groups in connection with corporate compliance plans.



News


January 2, 2025

Seth Orkand and Danielle Tangorre Co-Author First “Labs in Court” of 2025 – What’s Old is New Again for the DOJ in Q4 ’24

Government Enforcement and White-Collar Defense Team co-chair Seth B. Orkand and Health Law Group member Danielle H. Tangorre co-authored the article, “Laboratories in Court: A Full Circle” published in G2 Intelligence on December 18, 2024. Seth and Danielle kick off the New Year reviewing five cases resolved or filed by the U.S. Department of Justice (DOJ) in the fourth quarter of 2024, noting that many of the cases involved the same themes seen earlier in the year: lack of medical necessity; and kickbacks to telemedicine companies, medical providers, and independent marketers. While there has been significant focus on individual accountability, the authors highlight the DOJ’s continuing focus on labs’ taking proactive steps to ensure compliance, the medical necessity of the testing they bill for, and the careful monitoring of their sales and marketing staff. Read the article.

G2 Intelligence
January 2, 2025

Seth Orkand and Danielle Tangorre Co-Author First “Labs in Court” of 2025 – What’s Old is New Again for the DOJ in Q4 ’24

Government Enforcement and White-Collar Defense Team co-chair Seth B. Orkand and Health Law Group member Danielle H. Tangorre co-authored the article, “Laboratories in Court: A Full Circle” published in G2 Intelligence on December 18, 2024. Seth and Danielle kick off the New Year reviewing five cases resolved or filed by the U.S. Department of Justice (DOJ) in the fourth quarter of 2024, noting that many of the cases involved the same themes seen earlier in the year: lack of medical necessity; and kickbacks to telemedicine companies, medical providers, and independent marketers. While there has been significant focus on individual accountability, the authors highlight the DOJ’s continuing focus on labs’ taking proactive steps to ensure compliance, the medical necessity of the testing they bill for, and the careful monitoring of their sales and marketing staff. Read the article.

G2 Intelligence