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Courts Diverge in Challenges to CMS's Minimum Staffing Requirements for LTC Facilities

On May 10, 2024, the Centers for Medicare and Medicaid Services (CMS) published its Final Rule to implement minimum staffing standards for long-term care (LTC) facilities in the United States. However, as discussed in our...more

New Supreme Court FCA Decision Avoids Thorny Claim Questions, Reiterates Interest in Constitutional Challenge

In its most recent False Claims Act decision, the US Supreme Court opted for a narrow “claim” definition analysis, limiting its impact to those involved in the E-Rate program, but signaled interest in addressing the...more

DOJ Announces Over $2.9 Billion in False Claims Act Recoveries in Fiscal Year 2024

In a press release issued on January 15, 2025, the US Department of Justice released its annual statistics and announced that recoveries from False Claims Act settlements and judgments in fiscal year 2024 topped $2.9...more

Florida District Court Finds FCA Qui Tam Provisions Unconstitutional in Outlier Opinion

On September 30, 2024, US District Judge Kathryn Kimball Mizelle of the Middle District of Florida held in United States ex rel. Zafirov v. Florida Medical Associates, LLC that the qui tam provisions of the False Claims Act...more

CMS Publishes Final Rule for Minimum Staffing Standards for Long-Term Care Facilities

The Centers for Medicare & Medicaid Services (CMS) published its Final Rule today to implement a minimum staffing “floor” for nursing homes in the United States, as first announced on April 22. The Final Rule, which as...more

DC Circuit: Pro Tanto Rule in False Claims Act Cases Reduces Risk of Windfall Damages Recoveries

The US Court of Appeals for the DC Circuit issued an important opinion on August 30, 2022, that reinforces the seemingly obvious principle that the government is not entitled to windfall damages recoveries in False Claims Act...more

New York False Claims Act Recovery Highlights Growing Risk of Tax Claims Pursued as False Claims

The New York attorney general on March 2 announced a $105 million New York False Claims Act settlement against an individual hedge fund manager and his firm for alleged tax evasion based on allegations originally brought by a...more

Seventh Circuit Creates Third Standard in FCA Dismissal Authority Circuit Split

The Seventh Circuit’s novel statutory interpretation of the government’s dismissal authority under 31 USC § 3730(c)(2)(A) may have unintended consequences. ...more

Ninth Circuit’s Refusal to Consider Government Appeal of FCA Dismissal Authority Portends Trouble

Just as the government’s exercise of its statutory authority to dismiss non-intervened False Claims Act (FCA) qui tam cases was beginning to pick up steam, the US Court of Appeals for the Ninth Circuit has issued a new...more

Implications of FCA Extension to Conduct Involving Federal Reserve Bank Loans

The touchstone of the civil False Claims Act (FCA) is a false claim for government money or property. In most cases, the question of whether the claim—false or not—involves “government money” is easily answered. But that was...more

Recent Cases Confirm That FIRREA Remains Potent Civil Fraud Enforcement Tool for DOJ

Despite a proven ability to generate massive recoveries for the federal government and inflict severe financial pain on companies and individuals accused of violating it, the Financial Institutions Reform, Recovery, and...more

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