Guilt By Position: Re-Emergence Of The RCO Doctrine

Law360, New York (August 14, 2012, 1:14 PM EDT) -- In recent years, the federal government has made no secret of its intent to pursue individuals in addition to companies in its efforts to enforce health care-related statutes, rules and regulations. One of the primary weapons in the government’s arsenal is its revitalization of the responsible corporate officer (RCO) doctrine.

Under this doctrine, an individual in a position of authority is susceptible to criminal prosecution and/or exclusion from federal health care programs for the misconduct of others in the organization, even in the absence of evidence...
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