Implementation of the Sessions, Brand, and Granston Memos - On Demand Recording
Recorded On: 05/14/2019
Time: 90 minutes
Session Format: On Demand Recording
CLE Credit Available: No
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Please join our distinguished panel of thought leaders at the U.S. Department of Justice (DOJ), the U.S. Department of Health and Human Services, and the U.S. Department of Labor for an in-depth discussion of the Sessions, Brand and Granston Memos. On November 16, 2017, the Sessions Memo set forth the DOJ’s new policy that it would no longer issue any kind of binding sub-regulatory guidance without undergoing the notice and comment rulemaking process. The Brand Memo, issued on January 24, 2018, then instructed DOJ attorneys not to use their affirmative civil enforcement authority to convert other agencies’ subregulatory guidance into rules that could be used to establish a violation of law. These two memos, along with the January 10, 2018 Granston Memo, which set forth the factors to be used by federal prosecutors to dismiss qui tam FCA cases, together represent an important shift in how the False Claims Act will be enforced.
Level of Difficulty: Intermediate
- AHLA Member: $99
- Non-AHLA Member: $149
- Payers, Plans, and Managed Care Practice Group