Gregory Rosen Weighs In on False Claims Act Scrutiny, DOJ Self-Disclosure Policies for Healthcare Risk Management
Rogers Joseph O’Donnell PC shareholder Gregory P. Rosen was quoted in the September issue of Healthcare Risk Management discussing heightened federal scrutiny of healthcare compliance and fraud.
Rosen noted that the Department of Justice (DOJ) is using broad False Claims Act powers to pursue investigations into billing practices and pharmacy benefit managers, and emphasized the importance of understanding the DOJ’s updated corporate self-disclosure policy.
“What we are seeing in the healthcare fraud world is a lot of increased scrutiny through the use of the False Claims Act, civil investigative demands, and general criminal investigations into billing practices,” Rosen said. “There is ongoing litigation on the civil side relating to pharmacy benefit managers.”
Rosen also cautioned healthcare organizations to avoid being distracted by political disputes, stressing the need for robust compliance programs and proactive evaluation of internal practices.
“I do not view this as a partisan issue. This is a compliance issue,” he noted.
Rosen is a shareholder in RJO’s Washington, DC office. Before joining the firm, he served with the U.S. Attorney’s Office in Washington, where he led major prosecutions, giving him deep insight into federal investigations and enforcement priorities.