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In June 2016, AmSurg Corp. and Envision Healthcare Holdings, Inc. (Envision) announced they have signed a definitive merger agreement pursuant to which the companies will combine in an all-stock transaction. Upon completion of the merger, which is expected to be tax-free to the shareholders of both organizations, the combined company will be named Envision Healthcare Corporation and co-headquartered in Nashville, Tennessee and Greenwood Village, Colorado. The company's common stock is expected to trade on the New York Stock Exchange under the ticker symbol: EVHC. Bass, Berry & Sims served as lead counsel on the transaction, led by Jim Jenkins. Read more.

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Inside the FCA blogInside the FCA blog features ongoing updates related to the False Claims Act (FCA), including insight on the latest legal decisions, regulatory developments and FCA settlements. The blog provides timely updates for corporate boards, directors, compliance managers, general counsel and other parties interested in the organizational impact and legal developments stemming from issues potentially giving rise to FCA liability.

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How to Implement Effective Internal Controls to Prevent Corrupt Behavior and Minimize the Risks of Third Party Bribes in Foreign Clinical Research


May 9, 2012

Bass, Berry & Sims FCPA and healthcare fraud attorney, John Kelly, will co-present "How to Implement Effective Internal Controls to Prevent Corrupt Behavior and Minimize the Risks of Third Party Bribes in Foreign Clinical Research" at the American Conference Institute's 6th Annual Conference on FCPA and Anti-Corruption for the Life Sciences Industry. Co-presenters include Clivetty Martinez, Health Care Compliance & Privacy for Johnson & Johnson International, Inc., and Joseph Alesia, Senior Counsel, Ethics and Compliance/Legal for Baxter International Inc.

The presentation will cover:

  • Best practices for monitoring actions undertaken by HCPs, CROs, third parties and other consultants when interacting with local government officials during the clinical research process
    • how to establish procedures for ensuring local procedures are followed without exposing the company to potential FCPA violations -
    • establishing internal controls to detect and prevent local anti-bribery issues, particularly within foreign clinical research, sales and distribution operations – investigator, health ministry approval, patient payments
  • Distinguishing parameters for locally-accepted/expected "grease payments" vs. what is permissible under the FCPA – knowing where to draw the line regarding what does/does not qualify as a facilitation payment
  • Striking the balance between too much vs. too little oversight when managing and overseeing operations led by local third parties
  • UK Bribery Act - how companies are updating global compliance programs to address facilitation payments across international life sciences operations

Bass, Berry & Sims is proud to be a sponsor of this conference. For more information and to register, visit the conference website.

Download Document - FCPA and Anti-Corruption for the Life Sciences Industry Conference Brochure

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