Melissa L. Jampol, a Member of the Firm in the Health Care and Life Sciences and Litigation practices, in the firm’s New York office, was quoted in the Health Care Compliance Association’s Report on Medicare Compliance, in “In Okla. Hospital FCA Case Over Supervision, Top Executive and M.D.s Take the Hit Too,” by Nina Youngstrom.
Following is an excerpt:
The inclusion of Terrell and the six physicians in the settlement are an example of the Yates memo in action, says former federal prosecutor Melissa Jampol, who is with Epstein Becker in New York City. The Yates memo, formally called the Individual Accountability Policy, is DOJ’s blueprint for nailing culpable individuals when settling corporate fraud cases (RMC 9/14/15, p. 1). “This shows the strong influence of the Yates memo,” she says. Some people think the Yates memo is “confined to the criminal realm, but it also applies to the civil realm. The fact that Terrell held a senior leadership position and was directly responsible for billing put him squarely within the Yates memo’s concerns and the allegations were pointed directly at him at times,” Jampol says. In another civil case, the former CEO of Tuomey Healthcare System agreed to pay $1 million over the alleged part he played in the sweetheart deals that turned the South Carolina health system inside out (RMC 10/3/16, p. 1).