Preventative Measures No large healthcare company can afford to lose, as actual or potential customers, the 80 million Americans covered by federal
healthcare programs, such as Medicare and Medicaid. In large part to avoid the Medicare/Medicaid exclusion statute, pharmaceutical
companies are paying billions of dollars in penalties without a fight.
Robert Ullmann is a partner in the Boston law firm of Nutter McClennen & Fish LLP. He can be reached at