The Supreme Court of the United States in Universal Health Services, Inc. v. Escobar et al., weighed in on and embraced the implied certification theory of liability within the False Claims Act (FCA)....more
6/22/2016
/ False Claims Act (FCA) ,
False Implied Certification Theory ,
Federal Contractors ,
Health Care Providers ,
Implied Certification ,
Material Misrepresentation ,
Medicaid ,
Medicare ,
Mental Health ,
SCOTUS ,
Universal Health Services Inc v United States ex rel Escobar ,
Unlicensed Medical Providers
In today’s robust enforcement climate, most companies have taken at least the first steps towards establishing a formal corporate compliance program. The mere existence of such a program, however, will not by itself protect a...more
On July 12, 2015, the state of Wisconsin passed a budget that, along with many expected cuts, additions, and tweaks, unexpectedly repealed Wisconsin’s False Claims for Medical Assistance Act—the state’s version of the federal...more
The United States Court of Appeals for the Ninth Circuit prevented a False Claims Act (“FCA”) relator from receiving a share of a $19 million settlement stemming from the defendant’s alleged false billing on a nuclear cleanup...more
On July 14, 2015, CMS issued a report regarding its implementation of the Fraud Prevention System, which uses predictive analytics to manage government fraud and False Claims Act investigations. According to this report, CMS...more
On July 2, 2015, the United States Court of Appeals for the Fourth Circuit affirmed a $237 million judgment against Tuomey Healthcare System, Inc. (“Tuomey”), in a federal False Claims Act (“FCA”) case arising out of...more
Last week, a subsidiary of American fashion designer Ralph Lauren Corporation made global news for violations of The Foreign Corrupt Practices Act of 1977 ("FCPA"). In short, FCPA prohibits covered entities – i.e., those that...more