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First Circuit Adopts But-For Causation Standard for Kickback-Premised False Claims Act Actions

On 18 February 2025, the First Circuit Court of Appeals issued its decision in United States v. Regeneron Pharmaceuticals, Inc., determining that “but-for” causation is the proper standard for False Claims Act (FCA) actions...more

US Department of Justice Announces US$2.9 Billion in Fiscal Year 2024 False Claims Act Recoveries

On 15 January 2025, the US Department of Justice (DOJ) published its report (Report) announcing civil recoveries under the False Claims Act (FCA) for Fiscal Year (FY) 2024. The recoveries for FY 2024 exceeded US$2.9 billion,...more

The False Claims Act and Health Care: 2023 Recoveries and 2024 Outlook

On 22 February 2024, the US Department of Justice (DOJ) published the statistics for federal civil fraud recoveries in Fiscal Year (FY) 2023. The DOJ announced that the “government and whistleblowers were party to 543...more

US Department of Justice Announces US$2.68 Billion in Fiscal Year 2023 False Claims Act Recoveries

On 22 February 2024, the US Department of Justice (DOJ) published its report (Report) announcing civil recoveries under the False Claims Act (FCA) for Fiscal Year (FY) 2023. The recoveries for FY 2023 exceeded US$2.68...more

The False Claims Act and Health Care: 2022 Recoveries and 2023 Outlook

On 7 February 2023, the US Department of Justice (DOJ) publicly reported the statistics for federal civil fraud recoveries in Fiscal Year (FY) 2022. While the DOJ emphasized in its accompanying press release that “the...more

The False Claims Act and Health Care: 2021 Recoveries and 2022 Outlook

In a significant departure from the general downward trend in False Claims Act (FCA) civil fraud recoveries over the past half-decade —and as predicted last year —recoveries in Fiscal Year (FY) 2021 drastically increased...more

Qui Tam Quarterly - Risky Business: Health Care Investments Pose Acute False Claims Act Risk for Private Equity

This article analyzes emerging risks to PE firms that invest in the health care sector by examining the current enforcement landscape and significant FCA litigation; identifies key factors that increase FCA risk for PE firms...more

HHS Creates a Working Group to Increase Collaboration with DOJ

On 4 December 2020, the Department of Health and Human Services (HHS) announced the creation of a False Claims Act Working Group (Working Group), with the goal of enhancing HHS’s partnership with the Department of Justice...more

COVID-19: New DOJ Guidance on Inability-to-Pay Claims: What Companies Affected by COVID-19 Need to Know When Seeking Reduced Civil...

As many corporate practitioners know from experience, U.S. Department of Justice (DOJ) lawyers and federal prosecutors often factor a company’s inability to pay into corporate civil and criminal resolutions with the...more

COVID-19: Labs Beware! – EKRA Expands DOJ’s Enforcement Arsenal in the COVID-19 Fraud Battle

I. INTRODUCTION - As discussed in recent alerts, federal and state authorities have focused their enforcement efforts on combatting fraud related to the COVID-19 pandemic....more

COVID-19: Government Enforcement in the Time of a Pandemic

In recent days, federal and state authorities have prioritized enforcement related activities aimed at combatting fraud schemes arising out of the public uncertainty and desperation caused by the COVID-19 pandemic. ...more

K&L Gates Triage: Internal & External Health Care Investigations

In this episode, Mark Rush and John Lawrence discuss the federal government’s expectations related to health care organizations conducting internal investigations and demonstrating a commitment to compliance. The episode also...more

K&L Gates Triage: 2018 Health Care Fraud Takedown

Recently, the U.S. Department of Justice (DOJ) and Department of Health and Human Services (HHS) announced its largest ever national health care fraud takedown, resulting in charges against 601 diverse defendants including...more

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