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pamela melaone

Joined: Feb 13, 2014
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Country: Colombia
Province/State: Huila
City: Cañada
Health Care Self-Disclosure Protocols
Feb 13, 2014

In recent years the federal government has aggressively investigated and prosecuted pharmaceutical companies and health care providers for possible violations of anti-fraud, anti-kickback and other laws. These efforts have resulted in massive fines and financial penalties.
In the face of these dangers, participants in the health care market need to consider various ways to forestall or at least mitigate possibly crippling sanctions. One important means is to investigate and voluntarily disclose wrongdoing before the start of an investigation – of course, in the hope of convincing the authorities to forego charges altogether or at least substantially reduce the penalties that would otherwise be sought and imposed.

As logical as this approach seems, the results of self-reporting often fall short of expectations. In “Dilemma of Self-Reporting: The FCPA Experience,” Elkan Abramowitz and I describe how federal authorities seek to give companies an incentive to self-report misconduct. But, with the possible exception of the Department of Justice, Antitrust Division’s Leniency Program and the Internal Revenue Service’s Offshore Voluntary Disclosure Program, the benefit of self-reporting remains uncertain in many contexts.

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Farhad

Joined: Jun 13, 2008
Posts: 765 (view all)
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Gender & Age: Male, 67
Country: Iran
Re: Health Care Self-Disclosure Protocols
Mar 26, 2014

Pamela,
There are people and companies participating with good will.
But simultaneously, there are MAFIAs in this industry. The more in-efficient and corrupt an administration is, the more influential these MAFIAs are.
-------------------------------------------------------------------------------------------------- -------
Farhad


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