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DOJ Scrutiny of Gender-Affirming Care for Minors Raises Privacy Concerns for Providers

The US Department of Justice, along with several state attorneys general, has issued subpoenas and civil investigative demands to hospitals, physicians, telehealth companies, and pharmaceutical manufacturers engaged in...more

From Vulnerability to Violation: FDA Cybersecurity Requirements for Medical Devices and FCA Enforcement

In June 2025, the US Food and Drug Administration (FDA) issued a final guidance titled Cybersecurity in Medical Devices: Quality System Considerations and Content of Premarket Submissions (2025 Cybersecurity Guidance). This...more

Enforcement Notes from American Health Law Association’s Fraud and Compliance Forum

Representatives from the defense bar and the healthcare and life sciences industry recently met for the American Health Law Association’s Fraud and Compliance Forum. The conference programming covered an array of topics for...more

US Administration Ups the Ante for Gender-Affirming Care Providers With Legislative Proposal

The US Department of Justice has proposed legislation to the US Congress that would, if enacted, create a private right of action against healthcare professionals who provide gender-affirming care to children. The proposal...more

DOJ Announces First FCA Settlement with Medical Device Company for Cybersecurity Violations

The US Department of Justice’s settlement with Illumina, Inc. is a first-of-its-kind involving alleged cybersecurity deficiencies causing violations of the False Claims Act (FCA) based on FDA quality standards. The...more

16 States Challenge Gender-Affirming Care EO as DOJ Scrutinizes Hospitals, Doctors, and Pharma Manufacturers

On August 1, 2025, 16 state attorneys general filed a complaint in federal court in Massachusetts against the US administration seeking a declaratory judgment that President Trump’s January 28, 2025 Executive Order 14187,...more

OIG’s Advisory Opinion No. 25-08: Negative Opinion Highlights Potential Broad Reach of AKS

In a relatively rare move, the US Department of Health and Human Services Office of Inspector General (OIG) recently issued an unfavorable Advisory Opinion (No. 25-08) (Opinion) reinforcing the agency’s expansive view of the...more

Seventh Circuit Overturns AKS Conviction in DME Marketing Case

The US Court of Appeals for the Seventh Circuit recently issued a decision that has important implications for stakeholders in the durable medical equipment (DME), medical device, and telehealth space as well as future civil...more

Courts Diverge in Challenges to CMS's Minimum Staffing Requirements for LTC Facilities

On May 10, 2024, the Centers for Medicare and Medicaid Services (CMS) published its Final Rule to implement minimum staffing standards for long-term care (LTC) facilities in the United States. However, as discussed in our...more

Risk Adjustment Continues to be A Major Focus in Medicare Advantage

Medicare Advantage is the dominant Medicare delivery system, now covering 54% of all Medicare enrollees. With the increase in enrollment and federal spending, however, has come increased scrutiny from enforcement and...more

First Circuit Holds ‘But For’ Causation Required to Demonstrate Falsity in Kickback-Based FCA Cases, Growing Circuit Split

In United States v. Regeneron Pharmaceuticals Inc., the US Court of Appeals for the First Circuit held that when the government seeks to establish False Claims Act liability under the 2010 amendment to the Anti-Kickback...more

DOJ Officials Commit to Aggressive FCA Enforcement, Signal Its Value and Direction

In remarks delivered at the Federal Bar Association’s (FBA) annual Qui Tam Section Conference, Deputy Assistant Attorney General Michael Granston reiterated the US Department of Justice’s (DOJ or the Department) commitment to...more

Patient Assistance Programs – The Dos and Don’ts from HHS OIG

Patient assistance programs (PAPs) emerged to help patients who lack health insurance or prescription drug coverage obtain critical, and often, life-saving medications. This is especially true for rare disease patients, whose...more

FCA Enforcement Risk Remains for Rare Disease Stakeholders

In honor of Rare Disease Day on February 28, 2025, we will publish a series of posts throughout the month on As Prescribed and Health Law Scan, focusing on issues impacting the rare disease community....more

HHS OIG Sets Out Limited Guardrails for Patient Assistance Arrangements

In honor of Rare Disease Day on February 28, 2025, Morgan Lewis is publishing a series of posts on As Prescribed and Health Law Scan throughout the month of February on issues impacting the rare disease community....more

Healthcare and Life Sciences: Key Insights and Considerations for Stakeholders in 2025

This report compiles several important developments that shaped the healthcare and life sciences industries in 2024 and spotlights key areas to watch in 2025. Each section addresses either an industry sector within healthcare...more

Manufacturers Should Carefully Evaluate OIG’s Approval of Medicare Cost Sharing Subsidies in Clinical Trials

At the end of last year, the US Department of Health and Human Services Office of Inspector General (OIG) issued an Advisory Opinion (AO 23-11, the Opinion) in which OIG approved an arrangement where a medical device...more

CMS Publishes Final Rule for Minimum Staffing Standards for Long-Term Care Facilities

The Centers for Medicare & Medicaid Services (CMS) published its Final Rule today to implement a minimum staffing “floor” for nursing homes in the United States, as first announced on April 22. The Final Rule, which as...more

Mass. USAO Hints at Healthcare Fraud Enforcement Focus in Rare Disease Space at White Collar Crime Conference

The Boston Bar Association hosted its fifth annual White Collar Crime Conference on May 2, 2024, featuring prosecutors from the US Attorney’s Office for the District of Massachusetts (the Office) and the Office of the...more

Show Me the Data: What Does DOJ’s Data-Driven Investigative Focus Mean for Healthcare Stakeholders?

As noted in our recent LawFlash, the US Department of Justice’s (DOJ’s) COVID-19 Fraud Enforcement Task Force (CFETF) recently released its annual compilation report of its efforts to combat fraud related to pandemic relief...more

Once Again #1: Health Care Fraud Leads DOJ False Claims Act Recoveries in 2024

The US Department of Justice (DOJ) Civil Division released its annual fraud statistics on February 22, highlighted by False Claims Act (FCA) settlements and judgments exceeding $2.68 billion in fiscal year 2023. DOJ released...more

Trending in 2024: What Does the HCFAC Report Signal About Federal Enforcement Mechanisms?

The Health Care Fraud and Abuse Control Program (HCFAC), an annual report jointly issued by the US Department of Justice (DOJ) and Department of Health and Human Services (HHS), can be helpful in predicting DOJ and HHS...more

DOJ Offers Encouragement for Organizations Looking Into M&A Deals

At a recent Food and Drug Law Institute (FDLI) conference, Arun Rao, Deputy Assistant Attorney General for the US Department of Justice’s (DOJ’s) Consumer Protection Branch (CPB), reiterated DOJ’s “Safe Harbor Policy” with...more

CMS Announces Nursing Home Staffing Standards and Accountability Initiative

The Biden administration recently announced its much-anticipated proposed rule for implementing a minimum staffing “floor” for nursing homes in the United States and further launched a nursing home accountability initiative....more

False Claims Act Breakups Are Harder to Do in the District of Massachusetts

As we at Morgan Lewis pride ourselves on excellent client service, we feel it is our duty to provide critical dispatches from the romantic world of healthcare fraud. Specifically, we want to highlight developments in the...more

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