Under the Park Doctrine, the government may pursue a criminal misdemeanor offense against a responsible corporate officer based on the misconduct of the officer’s corporation, regardless of whether the officer had knowledge of the misconduct. Similarly, OIG may seek to exclude an officer or managing employee of a corporation based on the conviction or exclusion of the corporation regardless of whether the officer or managing employee had knowledge of the conduct giving rise to the sanction.

Debate whether the government should be permitted to invoke these authorities - either separately or combined - to impose consequences on corporate officers in the absence of any specific knowledge of wrongdoing. Is this a good or bad thing for our healthcare system?

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The debate over whether the government should be permitted to invoke the Park Doctrine and OIG exclusion authorities to impose consequences on corporate officers without specific knowledge of wrongdoi... View the full answer