The U.S. Supreme Court issued its decision on June 16, 2016, in Universal Health Services v. United States ex rel. Escobar, No. 15-7, a case the government contractor and health care communities hoped the Court would use to narrow the scope of liability under the federal False Claims Act (FCA). The Court did not oblige. Rather, a unanimous Court held that: (1) “implied certification” is a valid theory of liability under the FCA and (2) FCA liability for failing to disclose violations of legal requirements depends on the “materiality” of those requirements, not on whether those requirements were express conditions of payment.