Targeting Health Care Execs And Managers

Law360, New York (October 28, 2010, 4:27 PM EDT) -- For the first time in over a decade, the U.S. Department of Health and Human Services Office of Inspector General (OIG) issued new guidance on the implementation of its permissive exclusion authority. See OIG, Guidance for Implementing Permissive Exclusion Authority Under Section 1128(b)(15) of the Social Security Act (Oct. 20, 2010).

The new guidance sets forth nonbinding factors the OIG says it will consider in deciding whether to impose permissive exclusion on an officer or a managing employee of an excluded or convicted entity — regardless...
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