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Medicare Customer-Loyalty Programs

Foley & Lardner LLP

Seventh Circuit Court of Appeals Reiterates Validity of Objective Reasonableness Defense to FCA Claims

Foley & Lardner LLP on

In a 2-1 opinion issued on April 5, the Seventh Circuit Court of Appeals again held that an objectively reasonable interpretation of a relevant statute or regulation precludes the required finding of intent under the False...more

King & Spalding

OIG Approves Customer Loyalty Program Involving Pharmacy Products

King & Spalding on

On December 17, 2019, OIG published Advisory Opinion 19-06 approving a supermarket’s expansion of a loyalty program to allow customers to earn rewards points on out-of-pocket costs paid in connection with the purchase of...more

Dorsey & Whitney LLP

First Circuit Affirms Dismissal For CVS Caremark Under Public Disclosure Bar

Dorsey & Whitney LLP on

The FCA’s public disclosure bar precludes liability when a relator’s allegations have been publicly disclosed in a list of statutorily enumerated sources. Last week, the First Circuit added to the growing jurisprudence both...more

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