Yates Memo, Yates Memo, Yates Memo

Posted on
December 20, 2016

In September 2015, Sally Yates, an attorney for the DOJ wrote a memo stating that individuals were to be held accountable in corporate wrongdoing cases.

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As 2016 comes to a close, we want to take a step back and look at the actions the OIG and DOJ have taken over the year and how it may impact your physician contracts and strategy in 2017.

Here’s our take on the most important emerging trends for 2017.

In September 2015, Sally Yates, an attorney for the DOJ wrote a memo stating that individuals were to be held accountable in corporate wrongdoing cases. Since its release, the Yates memo has been one of the hottest topics in healthcare compliance. We have seen doctors as well as hospital executives fined for improper physician payments. This September, the former CEO of Tuomey Healthcare was fined $1 million for his role in the hospital’s Stark violations. He is also excluded from working for any organization participating in federal programs for the next four years.

The number of personal liability fines likely will increase in 2017. Thus, it is imperative that individuals including physicians, hospital executives, and those involved with physician contracting pay attention to how their actions could be perceived in any government investigation. Individuals can no longer assume the organization will be blamed for regulatory violations. Read more on our blog.

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