Government Enforcement, Investigations & Compliance

Government Enforcement And Investigations (bookbinder, Ngo, Savage, Mcpherson And Hodge)

Overview

With extensive experience successfully responding to a full range of criminal and civil enforcement actions and prosecutions, companies and their executives trust Choate with sensitive high-stakes matters, including those initiated by DOJ, HHS-OIG, SEC, FINRA, DOL and other federal agencies and states’ attorneys general. In particular, we:

  • Conduct internal investigations on behalf of organizations and special board committees
  • Represent companies, institutions, and individuals in criminal and civil government investigations
  • Defend clients in agency enforcement actions
  • Implement compliance programs and negotiate Corporate Integrity Agreements (CIAs), Consent Judgments, and Corrective Action Plans
  • Advise clients on disclosure obligations

Additionally, clients rely on us for timely and practical compliance advice and benchmarking based on enforcement trends and best practices.

Research security at U.S. universities and affiliated medical institutions has become a top government priority with increasing concerns about conflicts of interest, malign foreign influence, data security, theft of intellectual property, and integrity in science. Our research security and compliance services to educational institutions are nationally recognized by Legal 500 and include leading high-stakes internal reviews of research security practices for prestigious universities and academic medical centers and responding to funding agency inquiries and DOJ investigations on a wide range of research-related matters. Our team has helped numerous institutions favorably resolve identified issues, whether via self-disclosures, refunds, or settlement agreements.

We closely follow revisions to federal regulations and guidance documents governing academic research, including research security requirements (e.g., NSPM-33) and provide thought leadership on these issues via speaking engagements at national conferences, podcasts, and nationally distributed webinars.

Our deep compliance experience brings a uniquely practical approach to addressing the tough issues our clients face. From skilled white collar defense attorneys who apply lessons learned from prior and ongoing cases to those with significant in-house experience, our team works collaboratively to ensure clients benefit from our collective knowledge, risk identification and strategic analysis skills, and knowledge of current industry trends.

We counsel clients developing their compliance programs, offering scalable solutions based on the size and stage of their company, and as their compliance program matures, we perform program assessments to identify and advise on gaps and go-forward prioritization of risk management efforts. Our practice is built upon meaningful, enduring relationships with clients where we utilize significant understanding of their businesses to inform and shape our advice.

With a focus on the life sciences and healthcare industries, we advise legal and compliance departments alike on activities that may implicate the False Claims Act, Anti-Kickback Statute, HIPAA, Food, Drug and Cosmetic Act, CAN-SPAM Act, TCPA, and similar state laws.

Cybersecurity. Our team advises businesses and institutions responding to cybersecurity incidents, helping them recover, remediate, recoup, and mitigate further risk. This includes conducting internal investigations and cybersecurity reviews, preparing incident response plans, complying with federal and state data breach laws, interfacing with the FBI and other law enforcement agencies, and responding to follow-on class action or other litigation. We also retain and partner with sophisticated incident response and forensic investigation firms to assess the nature and extent of a cybersecurity incident.

Data Privacy. We represent companies and investors in a wide range of privacy-related matters across industries. With a depth of experience in HIPAA and state privacy laws, including web-tracking technology, we routinely advise healthcare companies and their business associates on developing and enhancing their policies and procedures, and in responding to patient complaints, audits, and government investigations.

Choate has a preeminent practice in representing public companies, private entities, officers, and directors in complex litigation and government investigations regarding securities, complex financial transactions, and corporate governance.  Dozens of corporate boards of directors and their committees rely on our team to handle highly sensitive matters.

Clients trust us to handle a broad range of litigation, internal investigations, and criminal and civil investigations by the Department of Justice, SEC, FINRA and other state and federal government offices and agencies.

Our team has extensive experience representing pharmaceutical and medical device manufacturers, academic medical centers, hospitals, and alternative service providers facing allegations of healthcare fraud in government investigations and related litigation, including alleged violations of the False Claims Act, Anti-Kickback Statute, Stark laws, and the Food, Drug and Cosmetic Act. Significant cases handled by our group have involved issues including off-label promotion, kickbacks, the operation of patient services programs, interactions with independent charitable patient assistance programs, the withdrawal of products from the market, engagement with electronic health records vendors, compliance with National Coverage Decisions, and upcoding and Medicare billing anomalies.

With many of our cases involving whistleblowers, we are experienced in conducting the internal investigations necessary to understand whether the allegations have merit. We are also experienced in litigating False Claims Act qui tam cases. Our market-leading talent enables us to provide an integrated response to allegations and to vigorously defend our clients in negotiations with government entities to resolve highly sensitive and brand–threatening matters as early and favorably as possible.

Why Choate for Government Enforcement, Investigations & Compliance?

Ge Proof Point 1 Go To Life Sciences, Healthcare And Higher Education Ge Proof Point 2 National Reach High Stakes Matters Ge Proof Point 3 35+ Litigators Ge Proof Point 4 Benchmark Across The Full Life Sciences Lifecycle

Academic Research Security & Compliance Experience

  • Represented premier university in connection with DOJ investigation and prosecution of faculty member for undisclosed financial and other ties to foreign institutions and a parallel civil proceeding in which the faculty member sought indemnification for their legal expenses.
  • Obtained favorable False Claims Act settlement following self-disclosure regarding university faculty member’s management of grant funds.
  • Coordinated response to law enforcement and conducted internal investigations related to malign foreign influence, conflicts of interest, and conflicts of commitment for multiple universities and teaching hospital clients.
  • Prepared self-disclosures and assisted institutions in calculating and managing refunds to multiple funding agencies (e.g., NIH, NSF, NASA, DARPA, ONR).
  • Represented teaching hospital in connection with attempted theft of biological specimens from research laboratory.
  • Led internal investigations and self-disclosures for university client to address time and effort and compliance with award condition deficiencies, resulting in favorable resolutions with no special award conditions or penalties.
  • Developed risk management strategies for university and teaching hospital clients to address conflict of interest and commitment concerns.

Compliance & Due Diligence Experience

  • Aided global pharmaceutical company in a proactive assessment of patient assistance program structure and compliance considerations.
  • Guided pre-commercial rare disease pharmaceutical company in a review of compliance considerations and patient assistance program structure in preparation for commercial launch.
  • Conducted royalties risk assessment for global medical device company involving a newly acquired entity.
  • Conducted assessment of compliance policies and procedures as part of Independent Review Organization team charged with reviewing multi-national pharmaceutical company’s compliance program.
  • Implemented compliance program addressing unique risks for medium-sized manufacturer of gene therapy products.
  • Helped vaccine manufacturer address compliance risks under an Emergency Authorization Use for a COVID-19 vaccine.
  • Advised Private Equity portfolio company in compliance program advising.
  • Partnered with compliance officer at medical device manufacturer to implement Corporate Integrity Agreement by leading required training and policy implementation and revisions.

Cybersecurity & Data Privacy Experience

  • Represent New England Patriots and Cape Cod Healthcare in separate, ongoing data privacy putative class action suits based on the use of web-tracking tools.
  • Represented global auction house in a putative class action data breach lawsuit, where we obtained a motion to stay the lawsuit and compelled arbitration, with the parties ultimately stipulating to dismissal of the matter with prejudice.
  • Counsel international cloud computing company on responding to law enforcement investigations into cybersecurity incidents and cybercrime perpetrated by nation-state actors, organized cybercrime groups, and other criminal actors.
  • Advised national transportation company on investigation of and response to incident involving unauthorized access to PII of thousands of individuals.
  • Advised a hospital system and insurance company in investigating and remediating a phishing-based cybersecurity incident that led to the exposure of Personal Health Information and unauthorized access to account information for thousands of institutional customers.

Healthcare Fraud Experience

  • Ongoing representation of global pharmaceutical company in government investigation relating to the execution of speaker programs and other kickback-related allegations.
  • Represented hospital in settlement of whistleblower lawsuit alleging false claims for cardiac procedure where National Coverage Determination criteria were not satisfied, and negotiation and implementation of related Corporate Integrity Agreement.
  • Represented multi-national medical device manufacturer in a federal criminal investigation and sentencing, and related qui tam action involving allegations regarding a voluntary product withdrawal, off-label promotion, improper reimbursement, and kickbacks in the form of evaluation product and payments.
  • Defended global biopharmaceutical company in a government investigation and qui tam litigation involving regulatory violations and marketing of compounded products.
  • Represented global pharmaceutical company in a government investigation of patient assistance program practices.
  • Represented home health agency in favorable and early resolution of whistleblower lawsuit alleging false claims.