Key Takeaways - The First Circuit ruled in United States v. Regeneron Pharmaceuticals, Inc., that the government must prove but-for causation to establish False Claims Act (FCA) liability based on violations of the...more
2/21/2025
/ Anti-Kickback Statute ,
Compliance ,
Department of Health and Human Services (HHS) ,
False Claims Act (FCA) ,
Healthcare Fraud ,
Life Sciences ,
Medicare ,
Pharmaceutical Industry ,
Risk Management ,
Safe Harbors ,
Whistleblowers
Is subjective intent relevant to FCA claims? The Court answered yes, holding that FCA liability turns on what the defendant actually believed, not on what an objectively reasonable person may have believed. On June 1, 2023,...more