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Sidley Austin says it published an update on healthcare self-disclosure programs
Sidley Austin said it published an update comparing two new Justice Department self-disclosure programs relevant to healthcare and life sciences companies, one criminal and one civil. The firm's article examined their different reporting routes and potential benefits, alongside questions about sequencing disclosures when conduct may create overlapping forms of exposure.
Key points
- Sidley Austin's article discussed the criminal disclosure policy issued by DOJ's National Fraud Enforcement Division and HHS-OIG on October 15.Sidley Austin
- The firm's update examined the six-month Healthcare False Claims Act Self-Disclosure Pilot Program announced October 22, with submissions due by April 22, 2027.Sidley Austin
- Sidley Austin’s article addressed the effect of whistleblower reports on disclosure timing.Sidley Austin
- The firm’s update discussed exposure under state law and other authorities that the programs would not resolve.Sidley Austin