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Attorney Spotlight

What is Shannon Wiley looking forward to at this year's Asembia Specialty Pharmacy Summit? Find out more>


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Experience Spotlight

Primary Care Providers Win Challenge of CMS Interpretation of Enhanced Payment Law

With the help and support of the Tennessee Medical Association, 21 Tennessee physicians of underserved communities joined together and retained Bass, Berry & Sims to file suit against the Centers for Medicare & Medicaid Services to stop improper collection efforts. Our team, led by David King, was successful in halting efforts to recoup TennCare payments that were used legitimately to expand services in communities that needed them. Read more

Tennessee Medical Association & Bass, Berry & Sims

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Thought Leadership

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Thought Leadership Spotlight

Download the Healthcare Fraud & Abuse Review 2017, authored by Bass, Berry & Sims

The Healthcare Fraud & Abuse Review 2017 details all healthcare-related False Claims Act settlements from last year, organized by particular sectors of the healthcare industry. In addition to reviewing all healthcare fraud-related settlements, the Review includes updates on enforcement-related litigation involving the Stark Law and Anti-Kickback Statute, and looks at the continued implications from the government's focus on enforcement efforts involving individual actors in connection with civil and criminal healthcare fraud investigations.

Click here to download the Review.

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 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.

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

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