f you’re the CEO of a healthcare company and the company’s been charged with fraud, can the CEO be found liable? It depends. If the government is able to prove that you had some knowledge that some improper billing activities were going on and you didn’t do anything about it to correct it, that could possibly subject you to criminal liability.

The other thing too is you can’t turn a blind eye to potential fraud or criminal behavior going on in your organization. What we call that is willful blindness and you can’t engage in willful blindness and say, well, if I don’t see it, I don’t pay attention to it, then I can’t be found liable for it.

If the government can show that you turned a blind eye and should have known that this was going on and didn’t do anything to stop it, it could potentially subject you to criminal liability.