Compliance, Investigations & White Collar


Home Health Care Continued to Be a Federal Enforcement Target in 2025
November 18, 2025 | Geoffrey R. Kaiser | Compliance, Investigations & White Collar | Health Services

The 2025 National Health Care Fraud Takedown, announced in June, was the largest in history, with 325 defendants charged (including 96 providers) in 50 federal districts. In all, the charged schemes involved more than $14 billion in intended loss, and more than $245 million in cash, luxury vehicles, cryptocurrency and other assets were seized. These

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The Intersection Between OMIG’s Home Care Audit Protocols and Liability Risk Under The False Claims Act
October 9, 2025 | Geoffrey R. Kaiser | Compliance, Investigations & White Collar | Health Services

OMIG publishes audit protocols to “assist the Medicaid provider community in developing programs to evaluate compliance with Medicaid requirements under federal and state statutory and regulatory law.”[1]  Such protocols are “applied to a specific provider type or category of service in the course of an audit and involve OMIG’s application of articulated Medicaid agency policy

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A History of CDPAP Enforcement at the NYS AG’s Office
September 10, 2025 | Compliance, Investigations & White Collar

New York’s Consumer Directed Personal Assistance Program (CDPAP) has long been the subject of enforcement at the New York State Attorney General’s Office (AG).  Many of those enforcement actions involve caregivers who billed Medicaid for CDPAP services never provided but sometimes also implicate agencies that are responsible for processing caregiver payments and protecting against fraud.

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The Feds Have Home Care Kickback Arrangements in Their Crosshairs
August 8, 2025 | Geoffrey R. Kaiser | Compliance, Investigations & White Collar | Health Services

The federal government has demonstrated that it is more than willing to use the United States criminal code to prosecute home care agencies that pay unlawful financial inducements to generate referrals in violation of the Anti-Kickback Statute (AKS).

In a superseding indictment unsealed in March 2025, the United States Attorney’s Office for the Eastern District

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FDA Issues Final Guidance for Industry Addressing Food Allergen Labeling Requirements
July 2, 2025 | Steven Shapiro | Compliance, Investigations & White Collar

The U.S. Food and Drug Administration (FDA) announced the availability of the Final Guidance for Industry: Questions and Answers Regarding Food Allergens, Including the Food Allergen Labeling Requirements of the Federal Food, Drug and Cosmetic Act (Edition 5). This final guidance is replacing all previously issued draft and final guidances by FDA concerning allergen labeling.

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COVID-19 Pandemic Fraud Enforcement Efforts Overview
May 23, 2025 | Geoffrey R. Kaiser | Compliance, Investigations & White Collar | Health Services

Jeff Kaiser’s article, “COVID-19 Pandemic Fraud Enforcement Efforts Overview,” was published on the Lexis Nexis legal research tool, Practical Guidance.

In the article, Jeff offers a comprehensive overview of enforcement efforts related to COVID-19 pandemic fraud.

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Quality of Care Considerations in OIG’s Nursing Facility Compliance Guidance
March 25, 2025 | John F. Queenan | Mary Aperance | Jeffrey Ehrhardt | Compliance, Investigations & White Collar | Health Services

John Queenan, Mary Aperance and Jeff Ehrhardt wrote, “Quality of Care Considerations in OIG’s nursing Facility Compliance Guidance,” for the spring 2025 issue of USLAW Magazine.

The article details the Industry Segment-Specific Compliance Program Guidance for Nursing Facilities (ICPG) and how the guidance may be used as a basis for investigations and enforcement actions.

To read

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FinCEN Engages in Outreach as CTA Deadline Looms
November 19, 2024 | Stella Lellos | Lindsay M. Brocki | Compliance, Investigations & White Collar | Corporate

WHAT:          A filing with FinCEN disclosing information about certain entities and owners.

WHO:             Nonexempt entities formed or registered to do business by filing a document with the state and the beneficial owners of such entities.

WHEN:          Companies formed prior to January 1, 2024, must file by January 1, 2025.

WHERE:        FinCEN’s Beneficial Owner e-filing system here.

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$68 Million CDPAP Fraud Indictment Unsealed Amidst Industry Changes
October 29, 2024 | Jeffrey Ehrhardt | Compliance, Investigations & White Collar | Health Services

On October 9, 2024, the United States Attorney’s office in the Eastern District of New York unsealed an indictment alleging that eight defendants defrauded Medicaid of approximately $68 million.[1] The alleged scheme involved two adult day care programs and a home care financial intermediary, all owned and controlled by the same individuals, as well as

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Investigating Quality Incidents
August 20, 2024 | Marc S. Ullman | Compliance, Investigations & White Collar

Even the best company is not perfect. Mix ups, mathematical errors, transposing numbers, forgetting to sign a batch production, a supplier mix-up, or any one of an almost infinite potential glitches in the very complex processes involved in making a dietary supplement can occur because human beings are not perfect. These events can range from

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