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CLE Approved – S1E2: From Audit to Accusation – A Smarter Way to Manage False Claims Risk

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We’re officially into episode two of Almost Clinical, and we’re already going to jump fearlessly into the deep end, confronting one of the healthcare industry’s biggest regulatory threats: the False Claims Act.

Through the FCA lens, what might begin as a routine audit can quickly escalate into a high-stakes fraud investigation. For providers, executives, and investors, the financial and reputational consequences can be staggering – even when there’s no intent to deceive.

In From Audit to Accusation: A Smarter Way to Manage False Claims Risk, hosts Vincent Buttaci, John Leardi, and Paul Werner draw from two decades of experience defending clients in payer audits, civil FCA litigation, and federal criminal prosecutions. They unpack how fraud investigations unfold, how regulators interpret “intent,” and why even an honest coding mistake can land your organization in the government’s crosshairs.

Highlights include:

  • Why fraud in healthcare is fundamentally different from other industries
  • How insurers and the DOJ infer “intent” from billing patterns
  • The myth of “simple mistakes” and why they offer little legal protection
  • The “should have known” standard and its sweeping implications
  • Why medical necessity documentation is often the deciding factor in FCA defense
  • How private equity ownership affects liability exposure
  • Strategic pitfalls for investors and executives during diligence and deal execution
  • The financial incentive behind fraud allegations – and who profits
  • Insights from DOJ proffer meetings, qui tam cases, and real-world audits
  • Why the fallout from an FCA case often extends far beyond a single lawsuit

Whether you’re a seasoned operator or evaluating your first deal in the healthcare space, Almost Clinical’s deep dive into one of healthcare’s most feared legal mechanisms is essential listening for anyone looking to mitigate risk in a landscape where compliance missteps are weaponized – and often monetized.

Join Almost Clinical hosts Vincent Buttaci, John Leardi, and Paul Werner as they challenge each other’s views on how to operate, invest, and succeed in healthcare’s rapidly shifting landscape, translate legalese into business sense for healthcare providers, executives, private equity professionals, and strategic stakeholders, and explore the issues shaping the business of medicine today and tomorrow.

  • Posted on: Dec 12 2025