The FCA continues to be the federal government’s primary civil enforcement tool for investigating allegations that healthcare providers or government contractors defrauded the federal government. In the coming weeks, we...more
In 2016, we let you know about the redundantly titled “Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015,” which required that heads of government agencies adjust civil penalties yearly to account for...more
The Department of Health and Human Services has issued new interim final rules to adjust a variety of Federal Civil Penalties for inflation. The Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015...more
The civil monetary penalties for violations of myriad health care laws continue to rise. In June, we discussed the enormous increase in penalties under the federal False Claims Act (“FCA”). Through an interim final rule, the...more
Thanks to section 701 of the Bipartisan Budget Act of 2015, Public Law 114–74, federal agencies have been forced to implement huge increases in penalties intended to deter health care fraud. The Federal Civil Penalties...more
On June 30, 2016, the U.S. Department of Justice (“DOJ”) announced an interim final rule almost doubling per-claim penalties under the False Claims Act (“FCA”). The FCA still imposes treble damages for government losses in...more
Under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, the Department of Justice (DOJ), Federal Trade Commission (FTC) and other agencies have raised the maximum civil penalties (CMPs) for legal...more
In an Interim Final Rule effective August 1, 2016, the Department of Justice (DOJ) confirmed increased statutory penalties under the False Claims Act (FCA) to adjust for inflation, almost doubling current penalty amounts. ...more
As anticipated, the DOJ follows the RRB’s lead, nearly doubling FCA penalties. In accordance with Section 701 of the Bipartisan Budget Act of 2015 (BBA), Public Law 114-74, the US Department of Justice (DOJ) published an...more
On May 6th, we posted about the possibility that the Department of Justice (“DOJ”) might dramatically increase False Claims Act (“FCA”) penalties after the Railroad Retirement Board (“RRB”) nearly doubled the per-claim...more
A preview of the effects that a provision in the Bipartisan Budget Act of 2015 will have on healthcare providers came to light this week when the Railroad Retirement Board (Board) published an interim final rule implementing...more
The penalties are potentially astronomical for entities with FCA exposure. In addition to treble damages, the False Claims Act (FCA) provides for mandatory penalties for each false claim submitted “of not less than...more