The Hillman Letter

The Hillman Letter · Featured · Latest · 2026-11-02

Zero Was True. The Claim Was Still False.

Six SNG dialysis centers pay about $2 million after reporting zero revenue to HRSA without disclosing a pre-arranged sale or closure. A true number in a misleading context still supports a False Claims Act theory.

Read on Substack
The Hillman Letter · 2026-10-26

1.25-1.6x Beats Treble: The Six-Month FCA Self-Disclosure Window

DOJ and HHS just put a price tag on coming forward: a 1.25 to 1.6x repayment for disclosing previously unknown civil False Claims Act issues. The clock runs to April 22, 2027.

Read on Substack
The Hillman Letter · 2026-10-19

The Spreadsheet Knew

Two September and October settlements show how a stalled internal review turns into a False Claims Act case. The 60-day overpayment clock is the reason.

Read on Substack
The Hillman Letter · 2026-07-06

Why family offices beat venture capital on early biotech. And where venture still wins.

On where family offices outperform venture capital on early biotech, and where venture still wins.

Read on Substack
The Hillman Letter · 2026-06-08

The hard road. Building a biotech of real value without operating in the gray market.

Issue No. 3 of The Hillman Letter, on building a biotech of real value without operating in the gray market.

Read on Substack

Full archive on thehillmanletter.substack.com.

The Hillman Letter · 2026-06-03

351(a) or 361. The pathway question that determines whether your biologic ever sees a BLA.

The fastest way to lose two years and four million dollars in early biotech is to pick the wrong pathway.

Read on Substack

Essays

White Paper · July 2026 · Federal & State Healthcare Law

The Architecture of Compliance: Federal and State Healthcare Law for the Practicing Physician

The False Claims Act, Anti-Kickback, Stark, HIPAA, EKRA, and qui tam whistleblower exposure, and the infrastructure that turns statutory knowledge into a defensible compliance record.

Read the white paper
Essay · 2026-06-11 · 1380 words

The Specific Pattern That Killed Five Biotech Programs I Personally Watched

The pattern was the same across five programs. In case you are running one of the next ones.

Read
Essay · 2026-06-10 · 1410 words

Why Dallas Is Quietly Becoming the Right Place to Build FDA-Regulated Biotech

The Dallas-Fort Worth biotech ecosystem has been compounding for three decades.

Read
Essay · 2026-06-09 · 1320 words

The 351 vs 361 Decision That Kills Most Exosome Programs

Why most exosome programs pick the wrong FDA pathway, and what the BLA route actually demands.

Read
Essay · 2026-06-08 · 1280 words

Why Family Office Capital Fits FDA-Regulated Biotech Better Than Venture Money

A ten-year venture fund has to return capital on a schedule. The FDA does not care about your schedule.

Read
Essay · 2026-06-07 · 1380 words

The Six Documentation Patterns That Show Up Before Federal Healthcare Enforcement

Every enforcement action I have served on involved a pattern visible eighteen to thirty-six months before.

Read
Essay · 2026-06-12 · 1480 words

What Thirty Years of Operating in FDA-Regulated Healthcare Actually Taught Me

Five lessons I would tell my younger self if I could.

Read
Medium · 2026-07-29

The Silent Killer of Biotech Startups: Ignoring the Full Legal Landscape

Argues that many biotech founders underestimate healthcare regulation and wrongly assume basic HIPAA or Anti-Kickback Statute awareness is good enough.

Read on Medium