Spencer Bruck
Overview
Spencer Bruck is counsel in Crowell & Moring’s Health Care group where he represents clients in litigation, fraud and abuse, and compliance matters. He recently joined the firm from the Office of the New York State Attorney General where he led civil health care fraud and qui tam investigations involving managed care organizations, pharmaceutical companies, national pharmacies chains, hospital groups, nursing homes, independent medical groups, and other providers.
Career & Education
- New York
Special Assistant Attorney General, 2021–2023
- New York
- University of Michigan, with distinction
- Georgetown University Law Center
- New York
- U.S. District Court for the Southern District of New York
- U.S. District Court for the Eastern District of New York
Spencer's Insights
Webinar | 09.13.24
Navigating the New MHPAEA Final Rule: Compliance and Enforcement Insights
On September 9, 2024, the U.S. Departments of Labor, Treasury, and Health and Human Services released a final rule implementing the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA). The rule clarifies and codifies the heightened standards that health plans and issuers are held to in documenting and ensuring MHPAEA compliance, amidst a landscape of increased regulatory enforcement and MHPAEA investigations. Given this heightened focus, it’s critical that plans and issuers proactively ensure compliance before regulators request required compliance documentation.
Client Alert | 12 min read | 09.13.24
Tri-Agencies Finalize NQTL Comparative Analysis Standards in Final Rule
Blog Post | 09.03.24
The Intricacies of Qui Tam Actions and the Role of Government Dismissals
Client Alert | 1 min read | 08.12.24
Representative Matters
- Conducted a qui tam investigation into a non-profit FQHC regarding False Claim Act allegations involving accounting for threshold visits.
- Conducted a qui tam investigation into a national pharmacy retailer regarding False Claim Act allegations involving partial-fill and restocking issues.
- Conducted a qui tam investigation into a hospital regarding False Claim Act allegations involving split/shared and physician supervision issues.
- Conducted a qui tam investigation into an independent medical group and a pharmacy regarding False Claims Act and Stark Law issues involving rehabilitation services and prescriptions.
- Conducted data analytics-driven investigation of MLTC regarding provision of services, retention of improper capitation payments, disenrollment, and compliance issues.
- Conducted data analytics-driven investigation into modifiers used by managed care organization.
- Conducted investigation into nursing homes involving patient neglect, understaffing, and financial fraud issues.
- Negotiated self-disclosure with HHS-OIG, USAO, and hospital group regarding Anti-Kickback Statute and Stark Law issues.
- Represented a multinational financial institution in a joint investigation by the Department of Justice and Securities and Exchange Commission into corruption issues in multiple international markets.
- Conducted an internal investigation for a medical device manufacturer into corruption issues in India.
- Represented a steelmaker in litigation through trial and a successful appeal regarding the breach of a natural gas transmission agreement.
- Represented a real estate investment firm in litigation against a joint venture partner regarding liquidation distributions.
- Represented a financial services company in a FINRA arbitration regarding customers trading options on futures contracts.
Spencer's Insights
Webinar | 09.13.24
Navigating the New MHPAEA Final Rule: Compliance and Enforcement Insights
On September 9, 2024, the U.S. Departments of Labor, Treasury, and Health and Human Services released a final rule implementing the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA). The rule clarifies and codifies the heightened standards that health plans and issuers are held to in documenting and ensuring MHPAEA compliance, amidst a landscape of increased regulatory enforcement and MHPAEA investigations. Given this heightened focus, it’s critical that plans and issuers proactively ensure compliance before regulators request required compliance documentation.
Client Alert | 12 min read | 09.13.24
Tri-Agencies Finalize NQTL Comparative Analysis Standards in Final Rule
Blog Post | 09.03.24
The Intricacies of Qui Tam Actions and the Role of Government Dismissals
Client Alert | 1 min read | 08.12.24
Insights
The False Claims Act: Compliance issues in US government procurement and healthcare
|08.07.24
Global Investigations Review
“Affirmative Action in the Law School at the University of Michigan: 1964-1972,” Michigan Journal of History, Winter
|2004
“Hedge Fund Report,” Paul Hastings Client Alert, Enforcement Section, Fall and Spring reports
|2012 - 2015
“New Extraction Payment Rule Requires Thoughtful Strategy,” Law360
|07/07/2016
“The Impact of Constitutional Liability and Private Contracting on Health Care Services for Immigrants in Civil Detention,” Georgetown Immigration Journal, Spring
|2011
New Federal Initiatives Increase Criminal Enforcement Concerns For Nursing Homes
|01.03.24
McKnights Long-Term Care News
The Intricacies of Qui Tam Actions and the Role of Government Dismissals
|09.03.24
Crowell & Moring’s Health Law Blog
Navigating the Attorney-Client Privilege Waiver Tightrope
|07.22.24
Crowell & Moring’s Health Law Blog
Settling False Claims Act Cases Involves More than Just Cutting a Check to DOJ
|06.17.24
Crowell & Moring’s Health Law Blog
Encouraging Signs that DOJ May Finally Be Using Its Dismissal Authority
|03.21.24
Crowell & Moring’s Health Law Blog
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03.19.24
Crowell & Moring’s Health Law Blog
Monumental Reduction in FCA Damages Based on Excessive Fines Clause
|02.15.24
Crowell & Moring’s Health Law Blog
Spencer's Insights
Webinar | 09.13.24
Navigating the New MHPAEA Final Rule: Compliance and Enforcement Insights
On September 9, 2024, the U.S. Departments of Labor, Treasury, and Health and Human Services released a final rule implementing the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA). The rule clarifies and codifies the heightened standards that health plans and issuers are held to in documenting and ensuring MHPAEA compliance, amidst a landscape of increased regulatory enforcement and MHPAEA investigations. Given this heightened focus, it’s critical that plans and issuers proactively ensure compliance before regulators request required compliance documentation.
Client Alert | 12 min read | 09.13.24
Tri-Agencies Finalize NQTL Comparative Analysis Standards in Final Rule
Blog Post | 09.03.24
The Intricacies of Qui Tam Actions and the Role of Government Dismissals
Client Alert | 1 min read | 08.12.24