A special committee of the Board of Directors of a large healthcare network hired Waller to conduct an internal investigation covering allegations of fraud, embezzlement, self-dealing, kickbacks, and other issues and violations. The initial investigation led to further analysis of potential healthcare violations (e.g., Stark and Anti-Kickback) and coordination regarding a response to a grand jury subpoena. Such violations, if true, could have led to possible False Claims Act liability.
The results of the investigation were presented to the special committee as well as the Board of Directors and led to substantial internal changes in policy and procedure, as well as the departure of several personnel, also negotiated by Waller attorneys. The investigation involved witness interviews, forensic document collection and analysis, and negotiations with multiple individuals, including Board members, c-suite executives and others.
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