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FCA Defendants and Counsel Beware: New DOJ Guidance on FCA Cooperation Credit May Leave Too Much to Prosecutors’ Discretion

In recent weeks, the United States Department of Justice (“DOJ”) published guidance in the Justice Manual at Section 4-4.112 on how it will award cooperation credit to entities and individuals that are being investigated for...more

Effective Internal Compliance Programs

Effective compliance programs continue to gain importance. Across all industries, it is imperative that meaningful compliance programs are in place and that they are regularly assessed to account for new risks and changes in...more

The Changing Landscape of FCA Litigation for Healthcare Providers Due to Increased Civil Penalty Amounts

Since the late 1990s, the False Claims Act (“FCA”) has heavily affected the healthcare industry. In 2015, two-thirds of FCA lawsuits targeted healthcare entities, which paid out $1.9 billion. However, it is likely that this...more

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