Universal Health Services, Inc. v. U.S. ex rel. Escobar, 136 S. Ct. 1989 (2016) was a landmark case in FCA jurisprudence. In Escobar, the Supreme Court held that the implied false certification theory can be a basis for liability under the FCA in some circumstances. The Supreme Court also held that the alleged contractual, statutory, or regulatory violation need not be expressly designated a “condition of payment” to trigger implied certification liability.
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