Is this you? As a journalist, you can create a free Muck Rack account to customize your profile, list your contact preferences, and upload a portfolio of your best work.
Claim your profile
Articles by Thomas E. Zeno
DOJ Remains Focused on Domestic Health Care Fraud | JD Supra
The Department of Justice (DOJ) recently issued its annual Health Care Fraud Takedown results, announcing a record-breaking 324 defendants, including 96 doctors and licensed professionals, as well as more than $14.6 billion in intended loss.
2 Changes Mean Contractors, Especially Small Businesses, Need to Prepare for AFCA | JD Supra
Government agencies may be eager to exercise their enhanced authority to investigate and pursue contractors under provisions in the newly enacted Administrative False Claims Act (AFCA). The two key changes discussed below could increase the number of claims that agencies may find appealing to investigate. Although these changes affect contractors of any size, small business contractors are likely to find investigations more disruptive if they lack a robust compliance program.
UK-Mexico Free Trade Agreement, Negotiations Formally Initiated to Finalize it Within Two Years
On May 20, 2022 the Secretary of Economy of Mexico, Tatiana Clouthier, and the Secretary of State for the Department for International Trade of the United Kingdom, Anne-Marie Trevelyan formally initiated negotiations towards a new Free Trade Agreement between both sovereignties, complying with their commitment to initiate talks within a year from the entry into force of the UK-Mexico Trade Continuity Agreement.
Avoid Turning One Data Breach into Two | JD Supra
When can a data breach get worse? When the process of notifying victims creates a second breach. Take the example of a cancer treatment center that recently paid $425,000 to settle allegations that included a faulty notification process following a breach. The story provides an important lesson. One Breach Leads to Another It began with a spear phishing attack. Employees at the facility fell victim to the attack and their email accounts were compromised.
Yes, I Want a Lawyer | JD Supra
It happens so often. An individual voluntarily talks with law enforcement agents in an effort to appear cooperative, but the prosecutor later labels the statements as incriminating “admissions.” Whether made before or after arrest, such statements prove compelling evidence.
Disclosure Crucial to Thousand Talents Investigations | JD Supra
China employs its Thousand Talents Program (“TTP”) to recruit overseas academic and scientific talent to work in China by promising research funding from the Chinese government and, occasionally, compensation. TTP has drawn increased scrutiny from the U.S. government, specifically the FBI and the Department of Justice, over purported concerns of intellectual property theft or espionage.
Top 5 Changes To Anti-Money Laundering Requirements | JD Supra
On January 1, 2021, the National Defense Authorization Act became law after Congress overrode the President’s veto. As highlighted below, Congress enacted a variety of key provisions that create significant and sweeping reforms to statutes and regulations designed to combat money laundering and terrorism financing. 1.
Disregard Compliance at Your Peril: Compliance Officer Paid As Whistleblower | JD Supra
A medical device manufacturer learned what might seem an obvious lesson when it paid $18 million to settle a False Claims Act lawsuit brought by its former Compliance Officer: don’t ignore your compliance officer. The federal government received $15.21 million; state governments received $2.79 million; and the whistleblower received $2.65 million of the federal share. The company, Merit Medical Systems, Inc.
National Criminal Takedown of Health Care Professionals | JD Supra
The Department of Justice recently announced the results of its 2020 National Health Care Fraud and Opioid Takedown. This annual DOJ tradition, aimed at targeting and arresting individuals for health care fraud abuse, resulted in the filing of criminal charges against more than 50 doctors and more than 20 health care executives. Prosecutions spanned the country, including more than 50 federal districts and 40 U.S. Attorney’s Offices.
Nursing Homes Face Scrutiny Following Financial Assistance
Release of $4.9 billion in financial assistance for nursing homes, which care for high risk seniors, is not all good news. Already facing difficult times, skilled nursing facilities will receive even more scrutiny to account for the money. Read tips here from former prosecutors Marisa Darden, David Maria, and Tom Zeno.
Growing Bullseye on Skilled Nursing Facilities
Although nursing homes appreciate the recent release of $4.9 billion in financial assistance, the bullseye on them continues growing. Troubles that preceded the COVID-19 crisis have gotten worse for facilities caring for high risk seniors. They face scrutiny over death rates from COVID-19, as well as how they will use relief money.
CARES Act Medicare Money - View From Former Prosecutors
The CARES Act requires Medicare providers to attest to multiple certifications. Former prosecutors examine how law enforcement may scrutinize these certifications. Marisa Darden, David Maria, and Thomas Zeno also offer tips on how providers who receive CARES Act funds can insulate themselves from scrutiny. Their article can be found here.
INSIGHT: CARES Act Medicare Money-A View From Former Prosecutors Original
A Medicare provider who accepts money from the Provider Relief Fund of the Coronavirus Aid, Relief, and Economic Security (CARES) Act accepts dozens of terms and conditions along with that money. These terms and conditions apply even if your entity receives unsolicited money that was automatically distributed based on your record of prior Medicare billing. Among these terms and conditions are multiple certifications to which the recipient must attest and which can have great ramifications.
FAQs for PPP from Small Business Admin.
The Small Business Administration provides Guidance in its Frequently Asked Questions (FAQs) for the Paycheck Protection Program to assist both borrowers and lenders. See analysis here in the Anticorruption blog by Kevin McCart, Claiborne Porter, Trevor Garmey, and Christina Knox.
New Trial at 6th circuit appeals for Dr. Paulus
Tuesday, April 7, 2020 A 2018 Sixth Circuit panel upheld a jury verdict convicting Dr. Richard Paulus of submitting fraudulent medical claims. That same panel, with 2020 hindsight(!), reversed that conviction. It held that the trial court’s order unconstitutionally blocked exculpatory evidence. Jury Verdict Set Aside The “twisted” history of the verdict began when a jury deadlocked twice and needed an Allen charge in order to convict Dr. Paulus of billing angiograms that were unnecessary.
“Twisted” Path to New Trial for Dr. Paulus
A 2018 Sixth Circuit panel upheld a jury verdict convicting Dr. Richard Paulus of submitting fraudulent medical claims. That same panel, with 2020 hindsight(!), reversed that conviction. It held that the trial court’s order unconstitutionally blocked exculpatory evidence. Jury Verdict Set Aside The “twisted” history of the verdict began when a jury deadlocked twice and needed an Allen charge in order to convict Dr. Paulus of billing angiograms that were unnecessary.
Whistleblowers Look To Capitalize On Stimulus
With their insider access to business operations, whistleblowers will follow stimulus money to learn whether the business abides by the strings attached to that money. Whistleblowers look for an opportunity to cash in on what they consider fraudulent conduct. What’s a business to do? See our discussion here on the Anticorruption blog.
Whistleblowers Watch Stimulus Money From Inside
Whistleblowers watch from inside when a business receives stimulus money. Whistleblowers, with their unique access to business operations, follow the money to learn whether the business abides by the strings attached to that money. Whistleblowers look for an opportunity to cash in on what they consider fraudulent conduct. What’s a business to do? Strings Attached We recently advised about the many strings attached to the trillions of dollars available from the stimulus packages.
That Money Comes With Strings – And Eyes | LexBlog
As tempting as it may be just to take stimulus money, remember that money comes with strings – and eyes. The stimulus packages establish requirements that must be satisfied (the strings). Moreover, watchdogs like the Department of Justice will be watching. See our discussion here on the Anticorruption blog.
DOJ's False Claims Priorities for 2020
The Civil Division’s priorities for pursuing recoveries under the False Claims Act during 2020 were discussed by Assistant Attorney General Joseph “Jody” Hunt. See a summary and analysis here by David Maria and Trevor Garmey in the Anticorruption blog.
DOJ Targets Nursing Home Care
Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice): Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below. Mondaq has a "free to view" business model.
International Sweep Against Elder Fraud
Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice): Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below. Mondaq has a "free to view" business model.
Nursing Home Care Focus of DOJ Investigations
You are responsible for reading, understanding and agreeing to the National Law Review's (NLR’s) and the National Law Forum LLC's Terms of Use and Privacy Policy before using the National Law Review website. The National Law Review is a free to use, no-log in database of legal and business articles. The content and links on www.NatLawReview.com are intended for general information purposes only.
International Sweep Against Elder Fraud
You are responsible for reading, understanding and agreeing to the National Law Review's (NLR’s) and the National Law Forum LLC's Terms of Use and Privacy Policy before using the National Law Review website. The National Law Review is a free to use, no-log in database of legal and business articles. The content and links on www.NatLawReview.com are intended for general information purposes only.
DOJ Targets Nursing Home Care
In a speech addressing elder abuse, US Attorney General Barr announced launch of a National Nursing Home Initiative. The Attorney General pledged to “bring to justice” owners and operators of nursing homes “who put profits before patients.” The Problem The Attorney General explained that he personally considers ending elder abuse a top priority and has made it one for the Department of Justice (DOJ).
International Sweep Against Elder Fraud
The US Department of Justice (DOJ) swept up more than 400 defendants for committing fraud against elder citizens this month. The sweep crossed international boundaries as DOJ attacked fraud against elders conducted by “transnational criminal organizations.” The sweep is part of DOJ’s overall attack against the five subtypes of elder abuse. Annual International Sweeps In order to highlight its importance, the sweep against elder fraud is an annual event.
Judge Tosses FCPA Jury Verdict - Government, Public Sector - United States
Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice): Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below. Mondaq has a "free to view" business model.
Judge Tosses FCPA Jury Verdict
On February 26, 2020, Judge Janet Bond Arterton, a federal judge for the District of Connecticut, overturned a former Alstom SA executive’s conviction under the Foreign Corrupt Practices Act (FCPA) relating to a project to build power plants in Indonesia.
Government Presses Extraterritoriality Of Wire Fraud Statute
Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice): Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below. Mondaq has a "free to view" business model.
Government Presses Extraterritoriality of Wire Fraud Statute
Skip to content
Department Of Justice Revises Policy On Self Disclosure Of Export Control And Sanctions Violations
To print this article, all you need is to be registered or login on Mondaq.com.
2019 Year-End White Collar Updates
Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice): Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below. Mondaq has a "free to view" business model.
Healthcare Recoveries Depend On Whistleblowers
Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice): Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below. Mondaq has a "free to view" business model.
DOJ Revises Sanctions And Export Self-Disclosure Policy
Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice): Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below. Mondaq has a "free to view" business model.
Extradition to US for Antitrust Violation
The US Department of Justice recently extradited an individual from Sicily to face an antitrust violation in the US. Barry Pupkin explains this is developing trend. Read his analysis here.
2019 Year-end White Collar Updates
In 2019, the US Department of Justice (DOJ) and other federal regulators continued to emphasize the importance of effective compliance programs, self-disclosure of violations of the law and cooperation with regulators during investigations.
DOJ Revises Sanctions and Export Self-Disclosure Policy
The National Security Division recently revised its policy on cooperation credit in order to align with other components of the U.S. Department of Justice. The changes, which are designed to “reassure companies,” are discussed in our client alert available here.
Healthcare Recoveries Depend on Whistleblowers
The government incentivizes whistleblowers in order to increase healthcare recoveries under the False Claims Act. See our analysis here of how the Act’s qui tam provisions work by Colin Jennings, Marisa Darden, and Ayako Hobbs.
False Claims Act Recoveries Back On The Rise
Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice): Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below. Mondaq has a "free to view" business model.
Healthcare Drives False Claims Act Recoveries
Once again, healthcare leads other industries for recoveries by the government and whistleblowers under the False Claims Act. Enforcement actions span the entire health care supply chain. See our report here in the Anticorruption blog.
False Claims Act Recoveries Back On The Rise
After a dip in the 2018 fiscal year, False Claims Act (FCA) settlements and judgments are back and climbing. The Department of Justice (DOJ) recently announced that it had obtained more than $3.05 billion from FCA settlements and judgments for the 2019 fiscal year. 2018 may have just been an aberration after the 2010s saw steady increases in FCA recoveries. This is particularly true because 633 new qui tam suits (12+ per week) were filed last year.
Fraudulent Cardiologist Was Very Busy
Registration (please scroll down to set your data preferences) Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaqs use of your personal data can be found in our Privacy and Cookies Notice): To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
Fraudulent Cardiologist Was Very Busy
Suspicious of the practices of one of its cardiologists, a hospital hired an independent expert to investigate. The expert examined records of 12 patients but “could not find support in any of the twelve cases” to implant pacemakers. The hospital terminated the doctor, and the government indicted him for health care fraud. During trial the government deployed an array of evidence including data mining, expert testimony, and evidence of an expensive lifestyle.
No Valentine for “Very Busy” Cardiologist Convicted of Fraud
Monday, January 13, 2020 After examining the body of evidence presented during trial, the Sixth Circuit refused to prescribe a new healthcare-fraud trial for Dr. Anis Chalhoub. A jury convicted the London (Ky.) cardiologist under 18 U.S.C. § 1347 for billing Medicare and other insurers for unnecessarily implanted pacemakers. Although “some of the government’s tactics here leave something to be desired,” a unanimous panel in US v. Chalhoub affirmed.
No Valentine for “Very Busy” Cardiologist Convicted of Fraud | Lexology
After examining the body of evidence presented during trial, the Sixth Circuit refused to prescribe a new healthcare-fraud trial for Dr. Anis Chalhoub. A jury convicted the London (Ky.) cardiologist under 18 U.S.C. § 1347 for billing Medicare and other insurers for unnecessarily implanted pacemakers. Although “some of the government’s tactics here leave something to be desired,” a unanimous panel in US v. Chalhoub affirmed.
No Valentine for "Very Busy" Cardiologist Convicted of Fraud
After examining the body of evidence presented during trial, the Sixth Circuit refused to prescribe a new healthcare-fraud trial for Dr. Anis Chalhoub. A jury convicted the London (Ky.) cardiologist under 18 U.S.C. § 1347 for billing Medicare and other insurers for unnecessarily implanted pacemakers. Although “some of the government’s tactics here leave something to be desired,” a unanimous panel in US v. Chalhoub affirmed.
U.S. and U.K. Ease Data Collection Across Borders - Data Protection - United States
Registration (please scroll down to set your data preferences) Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaqs use of your personal data can be found in our Privacy and Cookies Notice): To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
Congress Seeks Reform of Red Notice Abuse
Monday, November 25, 2019 A Red Notice allows for detention of an international fugitive. But the practice has been criticized for abuse. In response, a bipartisan group of Congresspersons have introduced the Transnational Repression Accountability and Prevention Act (“the TRAP Act”). This reform legislation, if enacted, will affect politically-motivated Red Notices and enforcement of them around the world.
How to Survive a Congressional Investigation
Learn from the experts how you and your organization can navigate a congressional investigation from start to finish. Our webinar on Wednesday, December 18, will help you understand the basics of a congressional investigation and what is required to avoid irreparable harm to business or reputation. Margaret Daum, partner and former Staff Director at the US Senate Committee on Homeland Security and Government Affairs and its powerful Permanent Subcommittee on Investigations, will lead the webinar.
Show More
loading
Actions
Is this you?
As a journalist, you can create a free Muck Rack account to customize your profile, list your contact preferences, and upload a portfolio of your best work.Get in touch with Thomas E.
Contact Thomas E., search articles and posts on X, monitor coverage, and track replies from one place.
Learn more about Muck Rack