Jonathan StevensJonathanStevens

Member of team appointed by the DOJ as an independent compliance monitor pursuant to a Deferred Prosecution Agreement related to alleged violations of the Foreign Corrupt Practices Act.

Conducted internal review on behalf of multinational medical device company into alleged misrepresentations made to the DOJ’s independent compliance monitor during the company’s Deferred Prosecution Agreement.

Advised multinational medical device company on obligations associated with the company’s Deferred Prosecution Agreement with the DOJ and the company’s Corporate Integrity Agreement with the OIG-HHS related to alleged violations of the Anti-Kickback Statute and False Claims Act and made presentations to federal monitors on the development of the company’s compliance and ethics program.

Drafted and submitted U.S. Health and Human Services, Office of Inspector General advisory opinion request on behalf of multinational oncology company.

Developed and conducted anti-bribery and anti-corruption training in EMEA, LATAM and APAC regions as well as targeted training to board of directors, corporate officers, finance, internal audit and other risk managers.

Developed and drafted numerous corporate policies and procedures addressing interactions with healthcare professionals, including company and third-party education and training events, sales and marketing practices, charitable donations and grants, consulting arrangements, as well as an internal fair market valuation process for hourly, clinical and royalty-based consultant arrangements.

Drafted and negotiated consulting agreements with domestic and international healthcare professionals, hospitals and teaching institutions on behalf of multinational medical device company.

Conducted product launch readiness assessment and compliance counseling related to patient-focused initiatives and support programs, including reimbursement/field support, data management, digital patient support platforms, free product and bridge programs for various rare disease companies.

Designing and vetting diagnostic and genetic testing programs offered by companies, including rare disease companies, to patients, including the test assay design, physician and patient messaging and disclosures, and data usage.

Conducted comprehensive product launch readiness assessments for numerous pharmaceutical companies, tailoring control enhancements to evolving risk profiles associated with particular commercial, medical and market access operational plans and strategies.

A multinational medical device company in voluntary disclosure to the U.S. Department of Justice related to potential violations of the Foreign Corrupt Practices Act in Brazil and other Latin American markets, resulting in a declination.

A multinational pharmaceutical company in connection with a U.S. Department of Justice subpoena and investigation into its patient support program, drug pricing and specialty pharmacy relationships, resulting in no actions taken by prosecutors.

A multinational pharmaceutical company in connection with a U.S. Department of Justice subpoena and investigation into rebate payments to pharmacy benefit managers, its patient support program and government price reporting, resulting in no actions taken by prosecutors.

A U.S. biopharmaceutical company in connection with U.S. Food and Drug Administration and U.S. Department of Justice investigations across multiple offices into its post-marketing approval study and sales and marketing practices with respect to a controlled substance, resulting in the sole civil-only opioid manufacturer resolution to date.

A multinational medical device manufacturer in connection with a voluntary disclosure to the U.S. Department of Justice related to potential violations of the Foreign Corrupt Practices Act in China and various other jurisdictions.

A multinational pharmaceutical company in connection with state attorney general investigation into patient support program benefits provided to employees of state employee healthcare plans.

Conducted internal investigation on behalf of domestic pharmaceutical company into whistleblower allegations of potential Anti-Kickback Statute violations related to clinical trials and advisory boards.

Conducted internal investigation on behalf of domestic pharmaceutical company into allegations of pre-approval promotion, off label promotion, and other sales and marketing practices.

Conducted internal review on behalf of specialty pharmaceutical company’s patient access programs and conducted internal investigation into alleged pharmacy fraud and abuse.

Conducted review on behalf of multinational medical device company into whistleblower allegations related to distributor conduct and potential Foreign Corrupt Practices Act violations in Brazil.

Conducted internal investigation on behalf of multinational medical device company into allegations of corrupt payments related to building permits in Mexico.

Conducted internal investigation and audit of third-party contractors in Vietnam on behalf of a multinational engineering and construction company in connection with a Foreign Corrupt Practices Act investigation before the U.S. Department of Justice and multilateral development banks.

Conducted internal investigation and audit on behalf of multinational medical device company in response to potential whistleblower allegations related to distributor conduct in Colombia.

Conducted internal investigations on behalf of multinational defense contractor into alleged improper subcontractor gratuities in violation of the Anti-Kickback Act, alleged conflict of interests in violation of the Procurement Integrity Act and whistleblower safety concerns related to the False Claims Act.

Conducted internal investigation on behalf of multinational defense contractor into alleged misappropriation of supplier trade secrets in anticipation of review by the U.S. Department of Defense’s largest Joint Program Office.

Conducted internal investigations under Federal Acquisition Regulation mandatory disclosure rule on behalf of multinational defense contractor, including overpayments on government contracts due to mischarging, violations of federal criminal law, fraud, conflicts of interest and false claims.