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How does Jessie Zeigler anticipate the intersection of privacy and smart technology will impact the future of litigation? 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

Healthcare Private Equity Compliance Checklist

The complex and ever-changing healthcare regulatory and enforcement environment, including increased focus on the role of private equity firms in their portfolio companies, make compliance a top priority for private equity firms investing in healthcare companies. The best way to limit your exposure as a private equity firm is to avoid a compliance misstep in the first place. Additionally, an effective and robust compliance program for your portfolio healthcare company makes it much more attractive to potential buyers and helps you avoid an unexpected and costly investigation or valuation hit down the road. Download the Healthcare Private Equity Compliance Checklist to assess whether your portfolio company's compliance program is up-to-date.

Click here to download the checklist.

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

Events

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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