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Joan H. Krause University of North Carolina (UNC) at Chapel Hill - School of Law August 8, 2012 Annals of Health Law, Vol. 21, No. 1, 2012 UNC Legal Studies Research Paper No. 2018589 Abstract: This essay considers how the 2010 Supreme Court decision in Skilling v. United States, which limited the situations in which mail and wire fraud cases may be premised on violations of the "intangible right to honest services," has the potential to alter the future of health care fraud litigation. While Skilling is widely perceived to have closed the door to several types of common mail and wire fraud prosecutions, this may not turn out to be the case in health care. In health care, the renewed focus on kickbacks as evidence of an honest services breach instead may dovetail nicely with both the Obama Administration's emphasis on criminal health care fraud enforcement and the jurisprudence of the Medicare & Medicaid Anti-Kickback Statute. This kind of leverage may prove very difficult for prosecutors to resist, and most certainly will require changes in the way the health law bar approaches common Anti-Kickback concerns. Number of Pages in PDF File: 10 Keywords: health care fraud, Medicare, white collar crime Accepted Paper Series Date posted: March 8, 2012 Suggested Citation Krause, Joan H., Kickbacks, Honest Services, and Health Care Fraud after Skilling (August 8, 2012). Annals of Health Law, Vol. 21, No. 1, 2012; UNC Legal Studies Research Paper No. 2018589. Available at SSRN: http://ssrn.com/abstract=2018589 Contact Information Joan H. Krause (Contact Author) University of North Carolina (UNC) at Chapel Hill - School of Law ( email ) Van Hecke-Wettach Hall, 160 Ridge Road CB #3380 Chapel Hill, NC 27599-3380 United States 919-962-4126 (Phone) 919-962-1277 (Fax)

GROUP OF SPRINGHILL SOUTH KOREA - In today's economic climate, who will help you protect your company and your clients from the devastating impact of fraud? Fraud can creep into your business in a number of ways. You may find you need an objective expert to deter potential problems, investigate allegations or provide resolution. A Certified Fraud Examiner (CFE) offers anti-fraud knowledge and skills you need to: * Investigate allegations against one of your employees * Recommend strong anti-fraud internal controls * Conduct interviews related to sensitive issues * Provide assistance with financial dispute resolution * Resolve irregularities discovered during your company's audit * Provide expert testimony on financial and investigative matters A Unique Set of Skills Fraud Examiners have a unique set of skills that are not found in any other discipline; they combine knowledge of complex financial transactions with an understanding of law, criminology, investigation and how to resolve allegations of fraud. CFEs work in a variety of disciplines including accounting, auditing, fraud investigation and security, as well as in different industry segments including government, healthcare, financial services, manufacturing and retail distribution. CFEs are knowledgeable in four areas critical to the fight against fraud: * Fraudulent Financial Transactions * Criminology & Ethics * Legal Elements of Fraud * Fraud Investigation Reduce Fraud Risks and Costs Heightened fraud awareness, combined with new laws and regulations, has increased the already growing demand in the workforce for professionals who are highly skilled at deterring, detecting and investigating fraud. CFEs have the ability to: * Identify and reduce opportunities for fraud * Implement effective anti-fraud controls * Continuously improve anti-fraud measures based on new risks and technologies * Educate employees to deter fraud and report wrongdoing * Resolve allegations

SPRINGHILLCARE'S BLOGSPOT - GROUP OF SPRINGHILL SOUTH KOREA - In today's economic climate, who will help you protect your company and your clients from the devastating impact of fraud? Fraud can creep into your business in a number of ways. You may find you need an objective expert to deter potential problems, investigate allegations or provide resolution. A Certified Fraud Examiner (CFE) offers anti-fraud knowledge and skills you need to: * Investigate allegations against one of your employees * Recommend strong anti-fraud internal controls * Conduct interviews related to sensitive issues * Provide assistance with financial dispute resolution * Resolve irregularities discovered during your company's audit * Provide expert testimony on financial and investigative matters A Unique Set of Skills Fraud Examiners have a unique set of skills that are not found in any other discipline; they combine knowledge of complex financial transactions with an understanding of law, criminology, investigation and how to resolve allegations of fraud. CFEs work in a variety of disciplines including accounting, auditing, fraud investigation and security, as well as in different industry segments including government, healthcare, financial services, manufacturing and retail distribution. CFEs are knowledgeable in four areas critical to the fight against fraud: * Fraudulent Financial Transactions * Criminology & Ethics * Legal Elements of Fraud * Fraud Investigation Reduce Fraud Risks and Costs Heightened fraud awareness, combined with new laws and regulations, has increased the already growing demand in the workforce for professionals who are highly skilled at deterring, detecting and investigating fraud. CFEs have the ability to: * Identify and reduce opportunities for fraud * Implement effective anti-fraud controls * Continuously improve anti-fraud measures based on new risks and technologies * Educate employees to deter fraud and report wrongd

GROUP OF SPRINGHILL SOUTH KOREA - MOBILE, Alabama -- Today, Melissa Garcia became the first in her family to graduate from college. "I'm so happy and I've made my parents so proud," said the 22-year-old Garcia, adding, "My parents come from poor backgrounds" and couldn't afford to attend college. She said her parents are her "inspiration." One of three children, the Houston resident received a bachelor's of arts degree in graphic design during Saturday's commencement at Spring Hill College. She was one of 300 graduates who made the walk down the historic Avenue of the Oaks on Spring Hill's campus for commencement. Garcia also is among the first group of Donnelly Scholars to complete their undergraduate degree. The Donnelly Scholars program was established in 2008 to serve first-generation college students at Spring Hill. The program is named in honor of the Rev. W. Patrick Donnelly, S.J, the 31st president of the college, who served from 1946 to 1952. Garcia said if she can't find a job in the Mobile area she plans to return home to Houston. "It almost feels a bit surreal," said 22-year-old Michelle Connor of Mobile as she waited to line up to receive her diploma. "It seems like we were just arriving on campus." Connor, who received her Bachelor of Arts degree in graphic design, is also a Donnelly Scholar. Connor is also job-hunting for something in her field. She said she's proud of what she's accomplished, but it's "frightening as well" being out there without a job. "Still, I'm ready to take the world head-on," said Connor. Senior Class Orator Brock Philip Boone, who graduated Magna Cum Laude, received mixed reactions during his speech, which drew some "boos" from the crowd when he told the graduates not to let Fox News and Rush Limbaugh sway their opinions. He received mixed reaction when he said the money the government is spending in Afghanistan could be better used funding education and feeding the poor. Sonja F. Bivins,