Saturday, December 17, 2016

Whistleblower's Standing & Silver v. Omnicare (Part 1)

Whistleblower's Standing & Silver v. Omnicare (Part 1)

In 1998, Medicare began paying nursing homes a fixed amount for their Medicare Part A patients, rather than reimbursing the homes for their prescription costs[1].  The change created a new financial risk for the nursing homes – the possibility that a Medicare Part A patient’s actual costs exceed what Medicare agreed to pay. 

Institutional pharmacies, like Omnicare, offered a solution: a package deal that provided, via kickbacks, below market pricing for Part A patients and above market prices for patients covered by Medicaid, Medicare Part D (beginning in 2006), and private insurance, whose prescription costs were paid as billed.  Because Part A patients were a small minority of all patients, this arrangement benefited the institutional pharmacies as well as the nursing homes, but Medicare and Medicaid lost out.  It was against the law, of course.

Marc Silver saw all this because he owned and operated a nursing home from 1986 through 2007 and an institutional pharmacy from 2001 through 2007.  He received proposals for this sort of kickback scheme from several institutional pharmacies, including Omnicare.  After accepting one of them, Silver’s nursing home saw its costs decrease by nearly 40% in 1999, and its profits increased.  Silver spoke with scores of nursing home owners in the years up to 2011 and found that they had enjoyed similar experiences. 

In 2010[2], David Gale filed a lawsuit, which the federal government joined, against Omnicare for its participation in these kickback schemes, based on evidence he had obtained as an employee of the company until he resigned in 2010.  In 2011, Silver filed his suit against Omnicare, Pharmerica, and three companies that they had acquired.  Silver’s suit was eventually joined by the federal government and 27 state governments under their various false claims acts.

The Gale and Silver cases proceeded[3] through the courts, based on slightly different, but mutually supporting, evidence.  In 2014, Omnicare settled the suits by agreeing to pay the federal government $124 million, of which Gale received $17 million.  Silver received nothing from Omnicare in the settlement although he could share in future state-level settlement agreements.

The 2014 agreement specifically excluded Pharmerica with whom Silver’s litigation continued.  Finally in 2016, the court agreed with Pharmerica that because Silver had had no commercial relationship with the company (he had relied on evidence provided by another and on public information, the court concluded) he was not entitled to file suit against it under the False Claims Act.

Silver’s case involves a few important questions about the nature of whistleblowing. 

First, who deserves to be called a whistleblower at all?  Silver was never an employee[4] of Omnicare or the other defendants in his suit; he never had to wrestle with the loyalty issues that confound other whistleblowers[5]; and he ducked the retaliations that employee-whistleblowers usually suffer[6].   Still, like any whistleblower, Silver served the public welfare by calling out a wrongdoing that he had witnessed. 

Omnicare dismissed Silver by calling his a parasitic suit that only built on Gale’s suit.  But companies accused of wrongdoing commonly disparage their accusers: their complaints are said to be, among other things, baseless and based in poor information, personal vendettas, and the product of character deficiencies.  For its part, HomeFirst claimed that my complaints were not always substantiated and that my responsibility as CFO was to fix problems, not report them externally.

Individuals well known as whistleblowers have been privy to critical information about wrongdoers who were not their employers.  Among the most famous whistleblowers is Daniel Ellsberg, who was a RAND Corporation analyst when he released the Pentagon Papers that revealed government deceptions about the war in Vietnam.  Edward Snowden was employed by Booz Allen Hamilton when he released secret government documents that described domestic and international surveillance programs.

Restricting the term whistleblower to current or former employees of the wrongdoer is an academic exercise that serves no useful social purpose and needlessly discourages evaluation of the disclosures.  While employee-as-whistleblower discussions can highlight the importance of combatting retaliation against whistleblowers, they divert attention from the more important wrongdoer-as-criminal conversation.

Second, were Silver’s motivations sufficiently pure?  When Sissela Bok wrote that whistleblowers should have a moral basis for their complaints, financial rewards for disclosures were rare.  Over the past 36 years, federal and state false claims acts have come to provide compensation for successful whistleblowers, as does the IRS among several federal agencies.  While support for whistleblower rewards is not universal, they have demonstrably increased the number of people (and their attorneys) willing to step forward despite probable retaliations, and in 2014 U.S. Attorney General Eric Holder acknowledged the need for financial rewards to properly compensate whistleblowers.

Whistleblowers’ motivations have always been a mix of ethical and base.  Those who make disclosures are often described as disgruntled and uncooperative, as well they might be around wrongdoers who ostracize and retaliate against them.  After I disclosed suspected misdeeds, HomeFirst was quick to accuse me of impeding the company’s doing business when I wasn’t sabotaging it.

Expecting that whistleblowers should be pure-hearted is delusional at best.  At worst, it subjugates potential whistleblowers to entrenched political and economic powers who are happy to infringe on others’ rights when it suits them.  If Silver’s motivation was, at least in part, financial there is no wrong in that, if only because Omnicare’s misbehavior was financially motivated.




[1] Information drawn from US et al ex rel. Marc Silver v. Omnicare et al Case 1:11-cv-01326-NLH-JS Document 65 Filed 09/19/13, Third Amended Complaint.  http://freepdfhosting.com/90b8ac4627.pdf
[2] Susan Ruscher, a former Omnicare employee, filed a similar suit in 2008, but courts decided that she failed to produce compelling evidence.  Ruscher’s most recent appeal was denied in 2016.  Alan Litwiller, another former Omnicare employee, also filed a suit over the kick-back scheme in 2011; it was dismissed in 2014.
[3] A hint as to how that process worked: Omnicare inundated Gale’s attorneys with almost half a million pages of evidence in response to their document request.
[4] Near, Janet P., Michael T. Rehg, James R. Van Scotter and Marcia P. Miceli.  “Does Type of Wrongdoing Affect the Whistle-Blowing Process?” Business Ethics Quarterly 14.2 (April 2004): 219-242
[5] Bok, Sissela.  “Whistleblowing and Professional Responsibilities.” In Ethics Teaching in Higher Education. Daniel Callahan and Sissela Bok (eds.).  New York and London: Plenum Press. 1980. 277-295
[6] Alford, C. Fred. Whistleblowers: Broken Lives and Organizational Power. Ithaca, NY: Cornell University. 2001; and Navex Global.  “2016 Ethics & Compliance Benchmark.” 

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