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How did a clerkship with Judge Merritt change the way Chris Climo approaches the practice of law? Find out more>


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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.

Wally Dietz and Lindsey Fetzer Examine Red Flags in the Anti-Corruption Context

Bloomberg BNA White Collar Crime Report


November 29, 2017

Bass, Berry & Sims attorneys Wally Dietz and Lindsey Fetzer authored an article for Bloomberg BNA's White Collar Crime Report discussing how an organization can identify and remediate anti-corruption red flags. Anti-corruption red flags are present in nearly any organization with multi-jurisdictional operations. However, the presence of a red flag doesn't suggest that a law has been violated, it is simply a suggestion of heightened risk. It's important for companies to proactively pursue and analyze red flags, and when necessary, correct potential issues.

Early identification of a red flag allows a company to stop problematic or high-risk practices before a trend emerges. Examples of potential anti-corruption risk areas can include hiring practices, political contributions or gifts, travel and entertainment. To identify the presence of risk indicators in these areas, companies can utilize various tools, including implementing risk assessments, encouraging employee and external reporting, and performing routine anti-corruption internal audits. 

If a red flag is identified through any of these methods, appropriate follow-up should be conducted. "Based on the severity and credibility of a potential allegation, this could include some type of anti-corruption internal investigation," explained the authors. "A properly scoped and conducted internal investigation can pay dividends to an organization." Following an investigation, the findings should be properly documented, and results should be examined and synthesized.

The full article, "Mitigating Risk: Identifying, Remediating Anti-Corruption Red Flags," was published in the November 24, 2017, edition of the Bloomberg BNA White Collar Crime Report and is available online (subscription required) or in the PDF below.

Download Document - Bloomberg BNA White Collar Crime Report (November 24, 2017)

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