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Texas Court Allows FCA Case to Proceed Based on Purchasing “Future Referrals”

In United States ex rel. Roshan v. E. Tex. Med. Ctr., 2020 U.S. Dist. LEXIS 252092, 2020 WL 8918651 (E.D. Tex. (Nov. 24, 2020)), a Texas federal court partially dismissed a relator’s claim alleging the defendants engaged in...more

Alleged Emergency Room Advanced Professional Practitioner Billing Scheme FCA Case Proceeds

In U.S. ex rel. Sonyika v. ApolloMD, Inc. et al., 2021 WL 1222379 (N.D. Ga. Mar. 31, 2021), a Georgia federal court allowed a relator’s Amended Complaint alleging a fraudulent scheme involving improper billing for services...more

Request to File Amended Complaint for Fraud Rejected for Failure to Allege Facts with Particularity

After granting defendants’ motion to dismiss and dismissing plaintiff’s action with prejudice, the U.S. District Court for the Middle District of North Carolina recently denied relator’s motion to alter or amend the judgment...more

Court Dismisses FCA Retaliation Complaint Involving Speaker Fees

In U.S. ex rel. Manieri v. Avanir Pharmaceuticals, Inc., 2021 WL 857102 (N.D. Oh. Mar. 8, 2021), the Northern District of Ohio dismissed a relator’s claim that he had been improperly retaliated because he had raised concerns...more

District of Minnesota Rejects But-For Causation in the AKS Context

In a recent opinion from the U.S. District Court for the District of Minnesota, the court analyzed the interplay between the False Claims Act and the Anti-Kickback Statute. See United States ex rel. Fesenmaier v....more

Reimbursement Consultant Could be Liable Under the FCA

The Northern District of Illinois recently denied a hospital reimbursement consultant’s motion for summary judgment, finding that the consultant could be held liable under the FCA based on the theory that the consultant’s...more

“Expert” Analyzing FOIA Report Barred as Public Disclosure

A federal district judge in the Northern District of California dismissed a qui tam suit in late 2020 under the public disclosure bar of the False Claims Act (“FCA”). United States ex rel. Jones v. Sutter Health, No....more

MedMal Plaintiff Uses Anti-Kickback and Stark to Avoid Summary Judgment

A federal court recently allowed a plaintiff’s state law negligence claim, which utilized the Anti-Kickback Statute (“AKS”) and federal physician self-referral law (the “Stark Law”) as legal support to survive a motion for...more

Federal Judge Dismisses False Claims Act Lawsuit Citing Advertisement as Public Disclosure

Recently, a federal judge in the Central District of California granted a Motion to Dismiss on behalf of a manufacturer of ophthalmic lenses alleged to have engaged in an illegal kickback scheme, based on the public...more

Updates on Third Party Involvement in Litigation Funding for FCA Cases

On January 27, 2020, Deputy Associate Attorney General, Stephan Cox, provided key note remarks at the 2020 Advanced Forum on False Claims and Qui Tam Enforcement. In his remarks, Mr. Cox noted that the Department of Justice...more

Sixth Circuit Holds Qui Tam Plaintiff a Government “Agent” for Public-Disclosure Bar

A recent Sixth Circuit opinion continues to “snuff [ ] out parasitic suits” brought under the False Claims Act (“FCA”) through the public-disclosure bar. In U.S. ex rel. Holloway v. Heartland Hospice, Inc. (June 3, 2020...more

Value-Based Purchasing and the False Claims Act: Tenth Circuit Finds Falsified Quality Data Immaterial Under Escobar

Last month, the Tenth Circuit upheld a grant of summary judgment in U.S. ex rel. Janssen v. Lawrence Memorial Hospital, 2020 WL 594508 (10th Cir. Feb. 7, 2020), applying the “rigorous” and “demanding” standard of materiality...more

DOJ announces $5.5 Million Settlement Concerning Allegations of Undisclosed Grants

On December 19, 2019, the Department of Justice (DOJ) announced that Van Andel Research Institute (VARI) has agreed to pay $5.5 million to resolve allegations that it violated the False Claims Act by submitting grant...more

DOJ Releases FY 2019 False Claims Act Statistics with Numbers that Highlight the Focus on the Healthcare Industry

The U.S. Department of Justice (DOJ) Office of Public Affairs recently released a report detailing the settlements and judgments from civil cases involving fraud and abuse claims obtained in fiscal year 2019. In total, the...more

DOJ Settlement Resolves Allegations of Individual Liability

On October 4, 2019, the U.S. Attorney’s Office for the Central District of California announced a settlement in which the Retina Institute of California Medical Group, its former CEO, and several of its physicians paid the...more

Tenth Circuit Affirms an Award of Attorneys’ Fees for a Successful FCA Defendant

On June 11, 2019, the Tenth Circuit affirmed an award of $92,592.75 in attorneys’ fees to the defendants in Pack v. Hickey, 776 F. App’x 549 (10th Cir. 2019). Pack had appealed the district court’s entry of summary judgment...more

“Health Care Fraud Impacts Everyone”: Miner Emphasizes DOJ’s Ongoing Dedication to Combatting Fraud

Matthew S. Miner, Deputy Assistant Attorney General of the Criminal Division at the U.S. Department of Justice, gave the keynote speech at the 29th Annual National Institute of Health Care Fraud, held in New Orleans, LA....more

DOJ Offers Further Guidance on False Claims Act Prosecutions

At a conference earlier this year, Deputy Associate General Stephen Cox offered further guidance on a number of topics central to the DOJ’s enforcement attitude in FCA actions over the past several years. Cox’s comments help...more

Certiorari Granted in Eleventh Circuit Case Interpreting Tolling Provision of FCA Statute

The Supreme Court recently granted certiorari in an Eleventh Circuit False Claims Act (FCA) case, Cochise Consultancy, Inc. v. U.S. ex rel. Hunt, No. 16-12836 (11th Cir. 2018). The Supreme Court will decide how the FCA’s...more

Eleventh Circuit Weighs In On FCA’s Alternate Remedies Provision

Due to the infrequency in which the situation arises, the FCA’s “alternate remedy” provision is infrequently invoked or discussed. In short, this provision states that when the relator presents information about a potential...more

Eleventh Circuit Expands the Divide on the FCA’s Statute of Limitations

The FCA’s statute of limitations, 31 U.S.C. § 3731(b), has been a source of confusion and disagreement amongst the courts and litigants for years. The disagreement is focused primarily on whether a relator in a non-intervened...more

Civil and Criminal Fraud and Abuse Penalties Increase and Stark Law Changes

The Bipartisan Budget Act of 2018 (the Act) continues to ratchet up penalties for fraud and abuse violations under the Medicare and Medicaid programs. The Act doubles statutory civil fines and quadruples some criminal fines,...more

Pleading with Particularity: Sixth Circuit Upholds Stringent Pleading Requirements in FCA Cases

In an effort to avoid transforming the FCA into “an all-purpose antifraud statute,” the Sixth Circuit recently reaffirmed that relators must plead a connection between the alleged fraud and an actual claim made to the...more

Seventh Circuit Looks to “Separate the Wheat from the Chaff” by Adopting a New FCA Causation Test

In United States v. Luce, the Seventh Circuit overturned a two-decade precedent by holding that proximate causation, and not “but for” causation, was the proper standard to employ in FCA cases. In so holding, the Seventh...more

Managed Care Quarterly Review: Issue 1

Tips for Managing Large Claims Disputes Part 1: Pre-Litigation Avoidance and Early Litigation Strategies - Large claims disputes brought by providers against payers are on the rise. Based on previous experience with dozens...more

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