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The False Claims Act Guide: 2023 and the road ahead

In the latest edition of our False Claims Act Guide: 2023 and the road ahead, we analyze the key developments from 2023 and discuss how the most important cases and issues are shaping FCA enforcement now and in the year to...more

OIG’s first-ever General Compliance Program Guidance covering all health care parties released

In November 2023, OIG released its first ever General Compliance Program Guidance (GCPG). The GCPG is a comprehensive document that applies to all individuals and entities involved in the health care sector....more

Sixth Circuit weighs in on meaning of causation, remuneration for False Claims based on alleged kickbacks

The Sixth Circuit expanded the existing circuit split regarding when a kickback causes a federal health care claim to be false or fraudulent under the False Claims Act (FCA) and set out a new analysis for what constitutes...more

After the Public Health Emergency: Implications for Medicare and U.S federal health care policies

On January 30, 2020, the Biden Administration announced that it intends to allow the COVID-19 national emergency and public health emergency (collectively, “PHE”) to expire effective on May 11, 2023. The termination of the...more

New circuit split on evidence needed to prove a kickback renders a claim false or fraudulent

The Eighth Circuit released an opinion Tuesday in U.S. ex rel. Cairns v. D.S. Medical LLC that creates a new circuit split on the interpretation of the causation standard for establishing that a claim “resulting from” a...more

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