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PODCAST: Williams Mullen's Benefits Companion - Government Investigative Demands
Host Jonathan Porter welcomes Husch Blackwell’s Catherine Hanaway to explore the government’s use of civil investigation demands (CIDs) within the context of False Claims Act investigations. The CID is a powerful and broad...more
On February 22, 2024, the U.S. Department of Justice (DOJ) released its annual False Claims Act (FCA) enforcement statistics for fiscal year (FY) 2023, which ended on September 30, 2023. While the $2.68 billion in total...more
A civil investigative demand (CID) is a tool, like a subpoena, that the government uses to obtain documents and information to investigate potential violations of the False Claims Act. The False Claims Act expressly...more
The Department of Justice (DOJ) has made numerous recent public statements reflecting increased priorities for enforcement, especially in the health care industry. The DOJ has a variety of tools at its disposal to enforce...more
The trend of private parties suing businesses under the False Claims Act, 31 U.S.C. § 3729 et seq (“FCA”) for violating requirements of the Paycheck Protection Program (“PPP” or the “Program”) continues. Just recently, the...more
The federal government has recently made clear its intention to go after healthcare providers who provide amniotic injections to certain Medicare and Medicaid recipients. Over recent years, the federal government has...more
One of the first indicators that may tip off a healthcare provider or government contractor that their organization may be the subject of a False Claims Act (FCA) investigation is contact with a government investigator. That...more
The United States Department of Justice (DOJ) is authorized by the False Claims Act (FCA) to issue Civil Investigative Demands, commonly known as CIDs. 31 U.S.C. § 3733. The DOJ has made increasing use of CIDs to obtain...more
A Civil Investigative Demand, often referred to as a “CID,” is a pre-litigation mechanism used to collect information and evidence for use in civil false claims act and other investigations. ...more
In Part 3 of our series on health care investigations, Mark Rush and John Lawrence discuss the process for external investigations conducted by federal and state governmental agencies, including in the context of qui tam...more
The Department of Justice (DOJ) recently backed down when a provider challenged DOJ's use of Civil Investigative Demands (CIDs) as part of an investigation into alleged violations of the False Claims Act (FCA). The case...more
Corporations and individuals engaged in a heavily regulated industry, particularly those doing business with the federal government, stand a good chance of being called upon to provide information related to a government...more
On September 9, 2015, the Department of Justice (the Department) publicly announced that it had issued guidance to its criminal and civil prosecutors that purports to change, at least in part, the Department’s approach to...more