The Department of Justice has been putting greater emphasis on the use of non-monetary tools, such as corporate integrity agreements, in False Claims Act enforcement, according to Assistant Attorney General Stuart Delery.
The DOJ is using non-monetary procedures to encourage organizations to operate in a manner that is compliant with the law. For example, corporate integrity agreements require healthcare providers to comply with numerous compliance obligations to prevent being excluded from the Medicare program by HHS.
Non-monetary procedures have not replaced monetary FCA enforcement measures, with the government already recovering more than $2 billion in FCA settlements and judgments in the first six months of 2014, according to a report from Inside Counsel.
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