News & Analysis as of

Liability False Claims Act (FCA) Health Care Providers

Pietragallo Gordon Alfano Bosick & Raspanti,...

Hidden Dangers Lurking in Corporate Integrity Agreements

When I litigated False Claims Act (FCA) cases at the U.S. Department of Justice (DOJ), it was common practice for settlements to require Corporate Integrity Agreements (CIAs) setting forth ongoing duties and responsibilities...more

Dentons

Ep. 45 – Update Your Return of Overpayments Policy to Align With CMS Changes to the 60-day Rule

Dentons on

Providers are required by federal law to return Medicare and Medicaid overpayments within 60 days of identifying the overpayment or they can be liable under the False Claims Act. Since 2016, providers have relied on Centers...more

Arnall Golden Gregory LLP

Seventh Circuit Affirms Liability in AKS-Based FCA Suit But Vacates Award of Damages

The United States Court of Appeals for the Seventh Circuit recently considered a district court’s nearly $6 million judgment in a qui tam False Claims Act (“FCA”) suit based on Anti-Kickback Statute (“AKS”) violations. The...more

Mintz

EnforceMintz — Some of 2023’s Largest FCA Resolutions Involved Stark Law Allegations

Mintz on

The Physician Self-Referral Law — known as the “Stark Law” — broadly prohibits physicians from profiting from self-referrals for “designated health services” (DHS) payable by Medicare or Medicaid. For example, the Stark Law...more

Bass, Berry & Sims PLC

False Claims Act Fundamentals: Reverse False Claims

Previous False Claims Act (FCA) Fundamentals posts have examined how violations of certain federal laws can potentially expose entities to FCA liability when they receive money from the government. This post focuses on how...more

Jones Day

Fourth Circuit Limits Who Can Act "Knowingly" Under False Claims Act

Jones Day on

Health care industry participants frequently operate under nuanced legal frameworks that apply to the receipt of government funds. A breach of these regulations can open the door to draconian liability under the FCA even when...more

Foley & Lardner LLP

Health Care Fraud Self Disclosure Protocol: You Discovered Misconduct… Now What?

Foley & Lardner LLP on

When a company decides to self-disclose misconduct (or conduct that may be construed as such) to the government, that decision triggers a stream of additional questions. In the weighty deliberations about whether and what to...more

Husch Blackwell LLP

50-State Update On COVID-19 Business Liability Protections - UPDATED March 2021

Husch Blackwell LLP on

A number of states have passed or are considering passing legislation to shield certain businesses from liability from claims for injury caused by exposure to COVID-19. Generally, the laws require that the business was in...more

Jackson Lewis P.C.

SCOTUS Declines To Decide Whether Objective Falsity Is Required To Establish Liability Under FCA

Jackson Lewis P.C. on

The question of whether the False Claims Act (FCA) requires a showing of objective falsity will continue to divide the circuit courts following the U.S. Supreme Court’s decision not to address the issue. To establish...more

Polsinelli

SCOTUS Declines to Review False Claims Act Cases on Falsity and Medical Judgment

Polsinelli on

On February 22, 2021, the United States Supreme Court declined to review two False Claims Act (FCA) cases, solidifying a split that pits the Eleventh Circuit against the Third and Ninth Circuits as to whether a disagreement...more

K&L Gates LLP

COVID-19: PPP Loan Borrowers - Your Information May Now Be Public

K&L Gates LLP on

On 19 June 2020, in a major reversal of the U.S. Department of the Treasury’s (Treasury) previous position, the U.S. Small Business Administration (SBA) and Treasury announced that they will publicize additional data...more

Sheppard Mullin Richter & Hampton LLP

Tips for the Unwary: Precautions Against Liability for Healthcare Businesses Receiving CARES Act Funds

The Coronavirus Aid, Relief, and Economic Security (CARES) Act provided trillions in economic relief in response to the COVID-19 pandemic, including hundreds of billions of dollars in aid for the healthcare industry....more

American Conference Institute (ACI)

[Event] False Claims and Qui Tam Enforcement Forum – Strategies to Respond to the Rapidly Changing Landscape of False Claims Act...

With more than 34.8 billion recovered by the government since 2010 under the federal False Claims Act, it has never been more crucial for private practitioners and corporate in-house counsel to keep abreast of the changes and...more

Bass, Berry & Sims PLC

No Consensus on Materiality: Courts Continue to Grapple with Escobar’s Key Holdings

Bass, Berry & Sims PLC on

Since the 2016 Supreme Court decision in Universal Services Inc. v. United States ex rel. Escobar, courts have wrestled with exactly how to apply the unanimous decision. This post highlights developments across the country in...more

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