How Conduct Abroad Impacts Health Care Business In US
By Alison Fethke, Devin Cohen, Haley Bavasi and Charles O’Toole (October 12, 2017, 12:05 PM EDT) -- Given the uptick in global awareness and enforcement of anti-bribery and corruption laws, most U.S.-based health care companies are attuned to the risks associated with legal infractions caused by their operations and conduct abroad. However, such ex-U.S. activities may also impact health care companies' ability to conduct business within the U.S. For example, overseas conduct could trigger exclusion, debarment or suspension from federal procurement of health care programs, such as Medicare and Medicaid, even if the alleged wrongdoing (e.g., conduct relating to bribery or corruption) occurs entirely outside of the U.S. and has no tie to any federal program. Further, quasi-government...
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