News & Analysis as of

Higher Education Act False Claims Act (FCA)

Ballard Spahr LLP

DOJ Announces New Initiative Aimed at Entities Receiving Federal Funds; Specifically Targets Higher Ed

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On May 19, the Department of Justice (DOJ) announced via a memo titled “Civil Rights Fraud Initiative” (the Memo) an initiative to use the False Claims Act (FCA) against federal contractors and recipients of federal funds...more

Morrison & Foerster LLP

New Executive Order Adds Scrutiny to Universities’ and Other Higher Education Institutions’ Foreign Sources of Funding

As a part of the new administration’s broader effort to add regulatory requirements and scrutiny to institutions of higher education, on April 23, 2025, President Trump issued an Executive Order (EO) on Transparency Regarding...more

Akin Gump Strauss Hauer & Feld LLP

Trump Administration Issues Executive Order Increasing Oversight of Foreign Funding at Universities

On April 23, 2025, President Donald Trump signed an Executive Order (EO) entitled “Transparency Regarding Foreign Influence at American Universities” and issued an accompanying Fact Sheet. The EO rekindles initiatives from...more

Dorsey & Whitney LLP

President Trump on Campus: New Higher Education Executive Orders

Dorsey & Whitney LLP on

Higher educational institutions have experienced outsized attention in the early days of the second Trump Administration. A trio of three recent executive orders suggests that the Administration’s focus on higher education is...more

Venable LLP

Are College Admissions Offices Minefields for Potential False Claims Act Liability Now?

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By now, the Supreme Court's June 2023 Students for Fair Admissions decision overturning affirmative action precedent, which Venable wrote about here, and has prompted institutions of higher education (IHEs) to review their...more

King & Spalding

Heightened Focus on Foreign Influence in Academia

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Department of Education Report Warns that Academic Institutions Are Failing to Meet Compliance Obligations in Fight Against Foreign Influence Last month the Department of Education (“DOE” or “Department”) released an...more

Bass, Berry & Sims PLC

With Widening Circuit Splits and Mounting Pressure, Will 2019 See a Post-Escobar Decision from the Supreme Court?

Bass, Berry & Sims PLC on

In 2016, the U.S. Supreme Court handed down its decision in Universal Health Services, Inc. v. U.S. ex rel. Escobar confirming the viability of the implied false certification theory in False Claims Act (FCA) cases and...more

Bass, Berry & Sims PLC

Ninth Circuit Holds that Escobar Set Forth Exclusive Conditions for Implied Certification Liability

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On August 24, 2018, the Ninth Circuit addressed the Supreme Court’s decision in Universal Health Services, Inc. v. U.S. ex rel. Escobar, holding that Escobar sets forth the exclusive test for establishing FCA liability under...more

Carlton Fields

Professional Services Exclusion Precludes Coverage for False Claims Act Suit

Carlton Fields on

It is not unusual for a directors and officers liability policy to have an exclusion for professional services. A such, a question often arises regarding whether the claimed wrongful conduct involved the rendering or failure...more

White and Williams LLP

Ninth Circuit Rejects Insured’s “Internal Business Practice” Argument and Enforces D&O Policy’s Broad Professional Services...

White and Williams LLP on

Earlier this week, in HotChalk, Inc. v. Scottsdale Insurance Company, No. 16-17287, 2018 U.S. App. LEXIS 14884 (9th Cir. Jun. 4, 2018), the Ninth Circuit Court of Appeals affirmed a District Court’s determination that a...more

McCarter & English, LLP

Universities Are Prime Targets for False Claims Act Liability

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Colleges and universities receive billions of dollars in federal funds, whether through research grants or student financial aid, or even by billing Medicare or Medicaid for services rendered at academic medical centers. As a...more

Carlton Fields

Whistleblowers on Campus: DOJ Adds Research Universities to its False Claims Act Focus

Carlton Fields on

Federal funding is the grand prize for higher education research institutions. Each year, the federal government pumps hundreds of millions of dollars in research grants and awards into the university system. These funds are...more

Bass, Berry & Sims PLC

Seventh Circuit Revisits Sanford-Brown, Rejects Implied Certification Claim

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In one of the few cases to apply the Supreme Court’s recent decision in Universal Health Services v. Escobar, the Seventh Circuit recently revisited and affirmed its prior rejection of an implied certification claim under the...more

Dorsey & Whitney LLP

Education Management Corporation Settles Significant FCA Claims

Dorsey & Whitney LLP on

Education Management Corporation (EDMC), a Pittsburgh-based company that operates for-profit educational institutions, has agreed to pay $96 million in what attorneys involved in the case claim to be the largest settlement...more

Sheppard Mullin Richter & Hampton LLP

Seventh Circuit Rejects FCA Implied False Certification Theory

On June 8, 2015, the U.S. Court of Appeals for the Seventh Circuit rejected the doctrine of implied false certification in a False Claims Act (“FCA”) lawsuit, U.S. ex rel. Nelson v. Sanford-Brown Ltd. No. 14-2506, 2015 WL...more

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