A cross-office team including health care counsel Alison Fethke (Chicago) and health care associate Devin Cohen (Boston) authored an Oct. 12 Law360 expert analysis article on how conduct abroad can affect U.S. health care business potentially triggering exclusion, debarment or suspension from federal health care programs such as Medicare and Medicaid.
The authors address the relationship between the Office of Inspector General of the U.S. Department of Health and Human Services OIG Exclusion Statue and the Foreign Corrupt Practices Act, as well as how health care companies with federal contracts should proceed in the event of debarment actions by quasi-governmental organizations such as the World Bank, given the potential impact on U.S. government business.
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