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Novel Ruling Raises Questions About Timing of Constitutional Challenges to the FCA’s Qui Tam Provisions

In recent months, False Claims Act (FCA) defendants have increasingly sought to challenge the constitutionality of the statute’s qui tam provisions. This trend gained momentum following Justice Thomas’s dissent in United...more

United States Files First Complaint Under the Civil Cyber-Fraud Initiative

On August 22, the United States filed its complaint-in-intervention (Complaint) against the Georgia Institute of Technology (Georgia Tech) and Georgia Tech Research Corp. (GTRC, collectively, defendants), asserting claims...more

False Claims Act Settlements to Know from Q2 2024

Halfway through 2024, the government’s False Claims Act (FCA) enforcement efforts show few signs of letting up. Last month alone, the Department of Justice (DOJ) announced at least five eight-figure FCA settlements,...more

12th Annual Healthcare Fraud & Abuse Review - A Critical Resource for Healthcare Providers

We are pleased to bring you our 12th annual Healthcare Fraud & Abuse Review. Our Review provides comprehensive coverage of the most significant civil and criminal enforcement issues facing healthcare providers. Each year, we...more

District Courts Wrestle with Causation in Kickback Cases While Circuit Courts Remain Divided

Two Massachusetts federal district courts recently addressed—and disagreed about—an important False Claims Act (FCA) issue that has also divided the federal circuit courts: when an alleged FCA violation is based on an...more

False Claims Act Fundamentals: Self-Disclosures

When healthcare providers and other government contractors are subject to scrutiny for bills submitted to the government, it is often the result of a whistleblower complaint filed under the qui tam provisions of the False...more

False Claims Act Decisions and Settlements to Know from Q4 2021

The final months of 2021 saw a flurry of noteworthy False Claims Act (FCA) activity. Among other developments, appellate courts issued important decisions concerning materiality, the government’s qui tam dismissal authority,...more

Changes Coming to the FCA?  Proposed Amendments Would Impact Materiality Analysis, Government Discovery, Among Other Issues

On July 26, Senator Chuck Grassley (R-IA) introduced a long-promised bill to amend the False Claims Act (FCA). Not-so-creatively entitled the False Claims Act Amendments Act of 2021 (S.B. 2428), the proposed legislation is...more

Recent FCA Cases Emphasize the Importance of Diligently Addressing Potential Overpayments

A common feature of False Claims Act (FCA) litigation is the pursuit of liability under the FCA’s so-called “reverse” false claims provision, 31 U.S.C. § 3729(a)(1)(G).  Reverse false claims liability applies when a person or...more

Escobar’s “Rigorous” Materiality Standard: Recent Developments – Part Two

This is the second post of a two-part discussion of recent developments related to the materiality standard set forth by the Supreme Court in Universal Health Services v. U.S. ex rel. Escobar. Read our previous post, which...more

Escobar’s “Rigorous” Materiality Standard: Recent Developments – Part One

This is the first post of a two-part discussion of recent developments related to the materiality standard set forth by the Supreme Court in Universal Health Services, Inc. v. U.S. ex rel. Escobar. Our second post will cover...more

Settlement Shows FCA Risks Posed by Non-Traditional Relators

On July 19, 2019, Myriad Genetics disclosed a $9.1 million settlement agreement to resolve a False Claims Act (FCA) qui tam lawsuit alleging that it engaged in a scheme to fraudulently bill Medicare for certain hereditary...more

District Courts Hold that DOJ Lacks “Unfettered” Discretion to Preemptively Dismiss Qui Tam Actions

In two recent decisions, federal district courts in the Eastern District of Pennsylvania and the Southern District of Illinois, respectively, considered the Government’s motions to dismiss False Claims Act (FCA) lawsuits...more

Supreme Court Agrees to Resolve Circuit Split on FCA Statute of Limitations

On November 16, 2018, the U.S. Supreme Court granted certiorari in Cochise Consultancy, Inc. v. U.S. ex rel. Hunt, agreeing to decide how the FCA’s statute of limitations applies in qui tam actions brought by a private...more

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