Recent Publications - Compliance, Investigations & White Collar
August 2, 2023 | |
Steven Shapiro and Marc Ullman wrote the article, “What Dietary Supplement Companies Can Do to Address Potential Counterfeiting of Their Products,” for the August 2023 issue of Nutrition Industry Executive.
The article explains how counterfeit products are going mainstream by moving to legitimate websites. It details how two dietary supplement companies determined that a fraudsters wereRead More
August 2, 2023 | |
In its August 2023 issue, Vitamin Retailer published Marc Ullman’s article, “Counterfeiting Headaches Aren’t Just for High Fashion Retailers and Designers Anymore.”
The article explains how counterfeiters have entered the dietary supplements market and how their products have been able to proliferate. It also offers some advice on how consumers and retailers alike can protect themselvesRead More
April 3, 2023 |
Under the Federal Food, Drug and Cosmetic Act, 21 U.S.C. 321(i), “cosmetics” are defined as “articles intended to be rubbed, poured, sprinkled, or sprayed on, introduced into, or otherwise applied to the human body or any part thereof for cleansing, beautifying, promoting attractiveness or altering the appearanceRead More
March 17, 2023 |
The FDA is facing possible legal action after three citizen petitions were rejected by the administration. All petitions were requesting that the FDA allow for the inclusion of CBD in dietary supplements, through some trade groups.
February 22, 2023 |
Jeff Kaiser’s article, “DOJ Issues New Guidance on Criminal Enforcement,” appeared in the winter 2023 issue of USLAW Magazine.
Click here to read the article.Read More
February 1, 2023 |
OMIG UPDATE: COMPLIANCE, SELF-DISCLOSURE, AND MANAGED CARE FRAUD, WASTE, AND ABUSE GUIDANCE POSTED
On the heels of publishing their final regulations, on January 31st, the Office of the Medicaid Inspector General (OMIG) released a variety of guidance documents addressing compliance programs; self-disclosure; and Medicaid managed care fraud, waste and abuse prevention programs. The guidance documentsRead More
January 6, 2023 | |
Marc Ullman was published in Natural Products Insider. His article, “Analysis: CBD food industry unlikely to placate FDA,” discusses the potentially negative impact on the FDA’s interpretation of the exclusionary clause in the Dietary Supplement Health and Education Act of 1994 (DSHEA). Ullman fears the current interpretation of the act will have a long lastingRead More
October 10, 2022 | |
On September 15, Deputy Attorney General (“DAG”) Lisa Monaco delivered remarks announcing updated guidance on how the Department of Justice will be prioritizing and prosecuting corporate crime. Her remarks were accompanied by a formal memo, titled “Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group” (https://www.justice.gov/opa/speech/file/1535301/download). However inelegant the title,Read More
August 10, 2022 | |
Healthcare fraud related to durable medical equipment (DME) is extremely costly to insurers yet often continues without criminal or civil consequences.
Fraudulent schemes by DME supply companies vary in complexity but usually prove extremely costly to insurers. Likely victims of DME fraud include Medicaid, Medicare, automobile insurers, workers’ compensation insurers, and other private health insurers.Read More
July 27, 2022 |
Marc Ullman authored the article, “FDA’s Misguided NDI Amnesty Scheme – But Companies Should Still Comply with the Law,” in the August issue of Nutrition Industry Executive.
Ullman discusses the FDA’s proposed guidance document on new dietary ingredients.
Read the full article here.Read More
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