Pharma Exec Criminal Convictions And HHS Program Bans

Law360, New York (January 29, 2013, 12:45 PM EST) -- For pharmaceutical executives facing criminal charges, the elephant in the room is the risk that a conviction will result in mandatory exclusion from participation in federal health care programs. As the Inspector General for the U.S. Department of Health and Human Services explained, “the practical effect” of such exclusion “is to preclude employment of an excluded individual in any capacity by a health care provider that receives reimbursement, indirectly or directly, from any Federal health care program.”[1] Of course, essentially every major health care provider receives...
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