2025 Healthcare Enforcement Priorities: A Discussion with Brook Andrews, Partner at Nelson Mullins

Episode Date: August 6, 2025

In this episode of Stark Integrity, Brook Andrews, Partner at Nelson Mullins, joins Bob Wade (Captain Integrity) to examine a critical topic for healthcare organizations:

The key enforcement priorities shaping healthcare compliance in 2025—and how organizations should respond.

The discussion delivers a clear message:

Healthcare enforcement is not going away—it is becoming more advanced and more targeted.

The Evolving Enforcement Landscape

Healthcare enforcement continues to expand in both:

• Scope
• Sophistication

Brook Andrews explains that government agencies are:

• Increasing coordination
• Leveraging more advanced tools
• Focusing on high-impact risk areas

The takeaway:

Enforcement is becoming smarter, faster, and more data-driven.

Enforcement Is Here to Stay

A central theme of the episode is:

Healthcare organizations should not expect enforcement pressure to ease.

Instead:

• Investigations will continue
• Oversight will intensify
• Expectations for compliance will increase

The key point:

Compliance is no longer optional—it is a core business function.

Who Is Being Targeted?

The discussion highlights that enforcement is not limited to:

• Intentional bad actors

It may also involve:

• Organizations with weak controls
• Providers with documentation gaps
• Entities that fail to monitor compliance effectively

The takeaway:

Even good-faith providers can be pulled into enforcement actions.

The Role of Government Tools

Brook Andrews emphasizes that enforcement agencies are:

Continuously improving their tools and capabilities.

These include:

• Data analytics
• Whistleblower actions under the False Claims Act
• Interagency collaboration
• Targeted audits and investigations

The key insight:

The government has more visibility into healthcare operations than ever before.

The Importance of Self-Auditing

One of the most practical recommendations from the episode is:

“Audit yourself.”

Organizations should:

• Conduct internal reviews regularly
• Identify potential risks early
• Address issues before they escalate

Because:

Internal audits provide an opportunity to correct problems before regulators find them.

Building a Culture of Transparency

Another key theme is:

Creating a culture of transparency within the organization.

This includes:

• Encouraging reporting of concerns
• Addressing issues openly
• Supporting compliance efforts across all levels

The takeaway:

Organizations that foster transparency are better positioned to manage risk.

The Big Picture: No Single Perspective

The episode uses the analogy of:

The blind men and the elephant.

This illustrates that:

• Enforcement is complex
• Risks can look different from different perspectives
• No single viewpoint captures the entire picture

The key point:

Compliance requires a comprehensive and coordinated approach.

Practical Compliance Strategies

To navigate 2025 enforcement priorities, organizations should:

• Strengthen compliance programs
• Use data proactively
• Conduct regular internal audits
• Monitor high-risk areas
• Maintain strong documentation
• Respond quickly to identified issues

Because:

Preparation is the most effective defense against enforcement risk.

Common Pitfalls

Organizations should avoid:

Reactive Compliance

Waiting for regulators to identify problems.

Weak Oversight

Failing to monitor operations consistently.

Poor Documentation

Lack of support for billing and services.

Ignoring Internal Signals

Overlooking early warning signs of risk.

The takeaway:

Most enforcement risk arises from preventable issues.

Key Takeaways

• Healthcare enforcement is increasing in sophistication
• Government tools and data capabilities are improving
• Both bad actors and good-faith providers may be targeted
• Internal auditing is essential
• Transparency strengthens compliance programs
• Enforcement requires a holistic approach
• Proactive compliance reduces risk

Final Thoughts

This episode highlights a critical reality for healthcare organizations:

Enforcement is evolving—and organizations must evolve with it.

With insights from Brook Andrews, the message is clear:

• Be proactive
• Strengthen internal controls
• Prioritize compliance at every level

Ultimately:

Organizations that take ownership of their compliance risks will be best positioned to navigate the enforcement landscape.

Because in today’s healthcare environment:

The best defense is not just responding to enforcement—it is staying ahead of it.

Click here to listen to this Stark Integrity Podcast Episode:
https://podcasts.apple.com/us/podcast/2025-healthcare-enforcement-priorities-a-discussion/id1588939373?i=1000720831453&l=fr-FR