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Choose Your Words Wisely: Hearsay Rules, Conspiracy, and Healthcare Fraud

The day-to-day operations of healthcare and the Rules of Evidence might seem unrelated, but in today’s enforcement environment, legal and compliance professionals can find, in evidentiary rules, best practices for creating a...more

Borrowers and Banks Beware: The New Year Brings the Nation’s First False Claims Act Settlement for Paycheck Protection Program...

On January 12, 2021, the Eastern District of California entered into a civil settlement with a Paycheck Protection Program (“PPP”) borrower and its CEO to resolve allegations of fraud. The settlement stemmed from a $350,000...more

Naughty or Nice: Feds Hand Out More Than Lumps of Coal When it Comes to Healthcare Fraud

The United States government has an arsenal of agencies and civil and criminal statutes at its disposal to choose from in investigating and combatting healthcare fraud.  A recent federal indictment discussed below exemplifies...more

DOJ Issues Consolidated Guidance for False Claims Act Cooperation Credit

The United States Department of Justice this month released a revised and consolidated set of guidelines for determining cooperation credit for organizations facing exposure under the False Claims Act. The consolidated...more

Grant-Fraud Guilty Plea Underscores Potential Civil and Administrative Liability for Recipients of Federal Funds

For most individuals and organizations, it does not get much worse than the threat of a criminal conviction. But for recipients of Federal funds—whether providers, grantees, or contractors—a federal criminal conviction is...more

Two Recent Justice Department Memoranda May Have Significant Consequences for Pending and Future False Claims Act Enforcement

In recent weeks, the United States Department of Justice (“DOJ”) issued two memoranda that might change the calculus of False Claims Act (“FCA”) cases. The memoranda at a minimum provide organizations with new—or at least...more

Supreme Court Upholds Implied Certification Theory of Liability; Imposes Limitations on its Reach

In a unanimous decision on June 16, 2016, the Supreme Court charted a middle course between competing interpretations of the scope of False Claims Act. Universal Health Servs., Inc. v. United States ex rel. Escobar, Case No....more

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