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First Circuit Adopts But-For Causation Standard for Kickback-Premised False Claims Act Actions

On 18 February 2025, the First Circuit Court of Appeals issued its decision in United States v. Regeneron Pharmaceuticals, Inc., determining that “but-for” causation is the proper standard for False Claims Act (FCA) actions...more

US Department of Justice Announces US$2.9 Billion in Fiscal Year 2024 False Claims Act Recoveries

On 15 January 2025, the US Department of Justice (DOJ) published its report (Report) announcing civil recoveries under the False Claims Act (FCA) for Fiscal Year (FY) 2024. The recoveries for FY 2024 exceeded US$2.9 billion,...more

Is It the End of the False Claims Act As We Know It? District Court Rules Qui Tam Provisions Unconstitutional

In a first-of-its-kind ruling on 30 September 2024, Judge Kathryn Kimball Mizelle of the US District Court for the Middle District of Florida held in United States ex rel. Zafirov v. Florida Med. Assocs., LLC that the qui tam...more

Long-Awaited Changes to Research Misconduct Rules Have Arrived

On 12 September 2024, the Office of Research Integrity (ORI) within the US Department of Health and Human Services (HHS) issued a final rule (Final Rule) that significantly modified the standards, procedures, and requirements...more

The False Claims Act and Health Care: 2023 Recoveries and 2024 Outlook

On 22 February 2024, the US Department of Justice (DOJ) published the statistics for federal civil fraud recoveries in Fiscal Year (FY) 2023. The DOJ announced that the “government and whistleblowers were party to 543...more

What's Been Missing: District Court Orders the Government to Produce Complete Universe of Claims in Provider's Due Process...

On 5 March 2024, in an issue of first impression in the District of South Carolina, a district court judge overseeing judicial review of a final agency decision in a Medicare claims appeal ordered the Government to complete...more

US Department of Justice Announces US$2.68 Billion in Fiscal Year 2023 False Claims Act Recoveries

On 22 February 2024, the US Department of Justice (DOJ) published its report (Report) announcing civil recoveries under the False Claims Act (FCA) for Fiscal Year (FY) 2023. The recoveries for FY 2023 exceeded US$2.68...more

Supreme Court Affirms Government's Broad Dismissal Authority in False Claims Act Suits

On 16 June 2023, the United States Supreme Court issued a decision in the case of United States ex rel. Polansky v. Executive Health Resources1, holding that the federal government (Government) maintains the authority to...more

Supreme Court Issues Decision Regarding False Claims Act's Scienter Element

The United States Supreme Court recently held that a defendant’s subjective belief is always relevant to the False Claims Act’s scienter element, regardless of what an objectively reasonable person may have believed. This...more

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