Ty Howard

Ty Howard

Bradley Arant Boult Cummings LLP

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Sixth Circuit Examines Materiality and Government Knowledge under the FCA

As its name implies, the False Claims Act (FCA) prohibits false or fraudulent claims to the federal government. Broadly construed, the FCA can apply to anyone receiving federal funds, but it is especially critical to...more

2/10/2015 - False Claims Act Federal Contractors Financial Institutions Health Care Providers Materiality

False Claims Act: 2014 Year In Review

In what is becoming an annual refrain, 2014 marked another year of robust False Claims Act (FCA) enforcement by the U.S. Department of Justice (DOJ) and mushrooming qui tam lawsuits by whistleblowers. Indeed, fiscal year 2014...more

1/19/2015 - Bank of America Banking Sector Banks BNP Paribas DOJ Enforcement Actions False Claims Act Federal Contractors Health Care Providers Janssen Pharmaceuticals JPMorgan Chase Kellogg Brown & Root Qui Tam Settlement Agreements SunTrust US Bank Wartime Suspension of Limitations Act Whistleblower Awards Whistleblowers

6 Questions To Ask Before An Internal Investigation

Every company, large or small, will eventually face a problem that requires an internal investigation. Boiled to its essence, an internal investigation is really nothing more than a way to obtain information to avoid or solve...more

12/16/2014 - Chief Compliance Officers Internal Investigations Risk Assessment

7th Circ. Limits FCA 'Worthless Services' Theory

On Aug. 20, 2014, the Seventh Circuit struck another blow against relators’ and the federal government’s increasingly aggressive False Claims Act theories of liability. Rejecting the relators’ use of the “worthless services”...more

9/12/2014 - False Claims Act FCA Worthless Services Claims

Seventh Circuit Limits “Worthless Services” Theory under False Claims Act

On August 20, 2014, the Seventh Circuit struck another blow against relators’ and the federal government’s increasingly aggressive False Claims Act theories of liability. Rejecting the relators’ use of the “worthless...more

8/29/2014 - False Claims Act Healthcare Healthcare Fraud Jury Verdicts Medicaid Medicare Worthless Services Claims

False Claim Act: 2013 Year in Review

Last year continued the trend of robust False Claims Act (FCA) enforcement by the U.S. Department of Justice (DOJ) and proliferating qui tam lawsuits brought by whistleblowers on behalf of the United States. In 2012, DOJ...more

1/15/2014 - Calculation of Damages CMS Compliance DOJ False Claims Act Federal Contractors FERA Fines First-to-File Fraud Halliburton Healthcare Medicare Off-Label Use Overpayment Pharmaceutical Physician Medicare Reimbursements Prescription Drugs Public Disclosure Qui Tam Wells Fargo Whistleblowers WSLA

The First Circuit Joins the D.C. Circuit in Hampering Relators’ Ability to Bring Duplicative Actions Under the False Claims Act’s...

The First Circuit has become the fourth federal court of appeals to address whether a first-filed yet insufficient complaint still qualifies as a pending action under the first-to-file rule of the False Claims Act....more

6/4/2013 - False Claims Act First-to-File Fraud Notice Requirements Pleading Standards

Courts of Appeals Continue to Limit the Government’s Aggressive False Claims Act Theories

This spring saw two significant victories for health care providers in the federal courts of appeals. In both cases, the courts rejected an aggressive government theory under the False Claims Act (FCA), the first related to...more

4/23/2013 - CIGNA Damages Diagnostic Tests False Claims Act FLSA Medicare MedQuest Physicians Supervision

The False Claims Act and Healthcare Providers: Key Results from 2012 and Likely Trends for 2013

From the perspective of False Claims Act (FCA) results, 2012 was a decidedly mixed year for healthcare providers. The bad news was quite bad—increased FCA scrutiny by the Department of Justice (DOJ) led to $3 billion of...more

1/7/2013 - Anti-Kickback Statute Attorney-Client Privilege DOJ Durable Medical Equipment Fashion Design Healthcare Medicaid Medicare Qui Tam Stark Law

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