We represented of a publicly traded oilfield services company in an investigation of alleged anti-corruption and money laundering violations in Africa. This representation included appropriate remediation and supplemental compliance program improvement. Reporting of findings involved extensive discussion – both written and oral – of the risks and benefits of voluntary self-disclosure.
Internal Investigation of FCPA Violations in Africa
Client Type: Public Company
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Representation of Envision Healthcare Corporation, Inc. in a DOJ/OIG investigation of allegations that allowing physician owners to share in anesthesia profits of Envision’s Folsom, California and Fresno, California ASCs violates the Anti-Kickback Statute.
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Lead counsel representing Traverse Anesthesia Assoc., an anesthesiology management company, in a DOJ investigation of False Claims Act allegations alleging fraudulent billing for medically-directed services, which resulted in declination by DOJ and negotiation of successful resolution of remaining allegations. U.S. ex rel. Stone v. Traverse Anesthesia Assoc. (TAA), PhyMed, (W.D. Mich.)
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Successfully represented a private equity backed portfolio provider and its management company in a voluntary disclosure to HHS-OIG involving improper billing