A New Jersey OB-GYN has settled a $5.25 million False Claims Act case and, as part of the settlement agreement, he has been excluded from Medicare and Medicaid for 20 years.
Exclusion of bad actors from federal programs is fairly common. HHS, DoD, and GSA each do about 4,000 exclusions a year.
In U.S. Dept. of Treasury v. Haider, (No. 0:15-cv-01518, D. Minn. 2016), a Minnesota District Court has held that a chief compliance officer can be held personally responsible for a bank’s failure to comply with the Bank Secrecy Act.