01.8.2018 | Articles / Publications
Burr Alert: Part IV: White Collar Courier: Delivering News and Providing Guidance in White Collar Matters
The new DOJ initiative – aggressively investigating and prosecuting pain management practitioners
Part Four: “Pill Mill” Red Flags and Strategies to Avoid Them.
In part one of this series, I detailed how the U.S. Department of Justice has focused its attention on the aggressive investigation and prosecution of “pill mill” cases. See “Part One: DOJ Devotes Resources, Vows to Come After ‘Pill Mills.'” In part two, I discussed what consequences doctors and other medical professionals could face as the result of a “pill mill” investigation. See “Part Two: What’s At Stake for Prescribing Professionals in ‘Pill Mill’ Cases.” In part three, I gave a detailed explanation of how the government investigates these cases. See “Part Three: Anatomy of a ‘Pill Mill’ Investigation.” In this last installment, I explain the red flags investigators look for and suggest practices that pain management professionals can implement in order to avoid government scrutiny.
I. RED FLAGS
As explained in part three of this series, the government has several investigative tools at its disposal in “pill mill” cases. Investigators use these tools to identify what they claim are “red flags” suggesting that the targeted medical practice is functioning as an illegal “pill mil.” The government will heavily rely on evidence of these supposed red flags at trial to establish that the doctor was prescribing drugs for an illegitimate purpose and outside the usual course of professional medical practice. For that reason, it is important for medical professionals to identify those red flags. Several of the red flags the government most often relies upon in these cases are as follows:
Download the full article, “Burr Alert: Part IV: White Collar Courier: Delivering News and Providing Guidance in White Collar Matters” written by Adam Overstreet.