DOJ’s Important Message to Health System Leadership


Michael Peregrine wrote this bylined article on how healthcare systems can deal with increased Department of Justice (DOJ) emphasis on individual accountability in fraud enforcement. The “new and notable intensity with which the DOJ is publicly making its point [is] emphasizing not only its focus on enforcement, but also on issues of executive accountability, corporate cooperation, and compliance plan effectiveness,” Mr. Peregrine wrote, as he urged general counsel to “frame the related internal discussion’ on compliance issues “that both the board and executive leadership should closely consider.”