paid $3 billion in a 2012 global settlement that included $1.5 billion in federal civil recoveries under the False Claims Act, $478 million in state Medicaid recoveries,and $1 billion in criminal fines and forfeitures. The settlement resolved allegations that the company (1) promoted the drugs Paxil, Wellbutrin, Advair, Lamictal, and Zofran for uses not approved by the U.S. Food and Drug Administration (FDA), known as off-label use, and paid kickbacks to physicians to prescribe those drugs as well as the drugs Imitrex, Lotronex, Flovent and Valtrex; (2) made false and misleading statements concerning the safety of the drug Avandia; and (3) reported false best prices and underpaid rebates owed under the Medicaid Drug Rebate Program. The $3 billion settlement is the largest health care fraud settlement in U.S. history. In addition, GSK signed a five-year corporate integrity agreement with the Department of Health and Human Services, Office of Inspector General (HHS OIG), to ensure compliance in the future. The settlement resolved multiple qui tam actions in which the relators received $131 million as their share of the settlement.

In the article regarding the GlaxoSmithKline settlement, there is a long discussion of the various actions taken by the company that led to the indictment and settlement.Identify one (1) issue that you feel is the least defensible among all of the company's actions and explain why you feel it is the least defensible.

• In contrast, identify one (1) issue that you feel is the most defensible among all of the company's actions and explain why you feel this is the most defensible.
• Given that the largest settlements over the past decade under the False Claims Act have been against large companies engaged in healthcare,why do you think that healthcare companies continue to be accused and convicted of huge False Claims Act violations?