News & Analysis as of

Motion to Dismiss False Claims Act (FCA) Health Care Providers

King & Spalding

Second Circuit Holds No FCA Violation Where Defendant Relied on Favorable OIG Advisory Opinions

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On April 14, 2025, the Second Circuit issued a summary order holding that the relator failed to plead scienter, a necessary element under the Anti-Kickback Statute (AKS) and the False Claims Act (FCA), where the defendant...more

Troutman Pepper Locke

The Beginning of the End for False Claims Act Qui Tam Cases? Florida District Judge Holds Whistleblower Provisions...

Troutman Pepper Locke on

On September 30, Judge Kathryn Kimball Mizelle held that the qui tam provision of the False Claims Act (FCA) violates the Appointments Clause of the U.S. Constitution because FCA relators are acting as “officers of the U.S.”...more

Polsinelli

Nursing Home Providers Suffer Blow as District Court Denies Motion to Dismiss in “Worthless Services” FCA Action Based on...

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On March 31, 2023, the United States District Court for the Eastern District of Pennsylvania dealt a blow to a trio of nursing home providers by denying their motion to dismiss a False Claims Act (FCA) claim brought by the...more

Foley & Lardner LLP

Court Calls Underlying Legal Standards “No Model of Clarity” but Allows False Claims Act Case To Proceed Anyway

Foley & Lardner LLP on

Does violating requirements amount to fraud under the False Claims Act (FCA) when the requirements allegedly violated are unclear? There is currently a circuit split and petitions for review pending to the Supreme Court as to...more

Akerman LLP - Health Law Rx

SCOTUS May Resolve Circuit Split on the Specificity Required of False Claims Act Claims: Relief or More FCA Grief for Providers?

Currently, providers have different risks of potential False Claims Act (“FCA”) liability depending on where they are geographically located due to the difference in the standards required by the U.S. Courts of Appeals...more

Miles & Stockbridge P.C.

Federal False Claims Act Wrap-Up - August 2020

A look at selected soon-to-be-reported decisions on various False Claims Act issues. This month we can glean three quick lessons...more

The Volkov Law Group

False Claims Act 2019 Year in Review

The Volkov Law Group on

Jessica Sanderson, Of Counsel at The Volkov Law Group rejoins us for her annual review of False Claims Act enforcement. 2020 marks the 150th anniversary of the Department of Justice (“DOJ”), and it unwrapped a nice gift:...more

Seyfarth Shaw LLP

In Case You Missed It: Guidance on Health Care Fraud Enforcement and Compliance

Seyfarth Shaw LLP on

The Houston Bar Association and the University of Houston Law Center Health Law & Policy Institute partnered to host the “Guidance on Health Care Fraud Enforcement and Compliance - A Conversation with HHS Counsel and Other...more

WilmerHale

Private Equity Firms, the Healthcare Industry, and the FCA: The “Butterfly Effect” in Action?

WilmerHale on

When Riordan, Lewis & Haden Inc. (RLH), a private equity firm, found itself ensnared in a False Claims Act (FCA) litigation for its role in a prescription drug kickback scheme orchestrated by one of its portfolio companies,...more

Hogan Lovells

FCA Alert: Decision Opens Door to Challenge of Agency Guidance in False Claims Cases

Hogan Lovells on

On November 5, 2019, the United States District Court for the Eastern District of Pennsylvania ruled on a motion to dismiss a False Claims Act (FCA) qui tam suit filed by the United States Department of Justice, long after it...more

McDermott Will & Schulte

Third Circuit Perpetuates Tuomey’s Controversial Stark Law “Volume or Value” Standard

The US Court of Appeals for the Third Circuit endorsed two controversial interpretations of the Stark Law’s “volume or value” standard, known as the correlation theory and the practice “loss” theory in U.S. ex rel. J. William...more

Baker Donelson

Plausibility Requirement for Pleading in FCA Cases Remains a Viable Defensive Tool

Baker Donelson on

The recent federal court opinion issued in United States ex rel. Integra Med Analytics, LLC v. Baylor Scott & White Health, et al, illustrates the continued importance of examining the plausibility of allegations made in qui...more

McDermott Will & Schulte

Remuneration? Not If It’s Fair Market Value, Says Eleventh Circuit

Bingham v. HCA, Inc., a recent Eleventh Circuit case, highlights the centrality of fair market value to Anti-Kickback Statute (AKS) analyses. This decision is significant for several reasons and we expect to see Bingham cited...more

K&L Gates LLP

Qui Tam Quarterly: The Department of Justice False Claims Act Policy Issue

K&L Gates LLP on

In this second installment of Qui Tam Quarterly, K&L Gates breaks down two policy statements by the U.S. Department of Justice ("DOJ"), providing an analysis of both (1) the 2018 "Granston Memo" and related case law; as well...more

Mintz - Health Care Viewpoints

Health Care Fraud Investigations and Litigation Offer Unexpected Lessons for Bankruptcy Counsel

WHAT’S INSIDE - Who Decides How Bankruptcy Laws Are Applied? PROMESA: An Experiment Doomed to Fail - The Role of Alter Ego in Restructuring - SPECIAL FRAUD SECTION - Don’t Depend on a Handshake - Health...more

Bass, Berry & Sims PLC

Government Files Amended FCA Complaint Against Private Equity Firm and its Portfolio Company

On March 18, 2019, the Department of Justice (DOJ) filed an amended complaint-in-intervention in the False Claims Act (FCA) case against Diabetic Care Rx, LLC d/b/a Patient Care America (PCA); two of PCA’s executives; and the...more

Dorsey & Whitney LLP

Another Qui Tam Suit Alleging a Scheme to Defraud by Reporting Inflated Drug Prices Survives Motion to Dismiss

Dorsey & Whitney LLP on

Within the last five years, district courts in the Seventh Circuit have repeatedly denied motions to dismiss qui tam lawsuits brought under the FCA that allege a scheme to defraud government health programs by reporting...more

Baker Donelson

The Aftermath of the DOJ Granston Memo

Baker Donelson on

The Director of the Civil Fraud Section of the Department of Justice (DOJ), Michael Granston, issued a memo in January 2018 noting the recent increase in qui tam lawsuits filed under the False Claims Act (FCA). The Granston...more

Seyfarth Shaw LLP

Management Alert: DOJ Files Motion To Dismiss Eleven False Claims Act Suits

Seyfarth Shaw LLP on

Seyfarth Synopsis: The United States Department of Justice recently filed a seismic motion to dismiss in a series of healthcare fraud-related cases. ...more

Arnall Golden Gregory LLP

Tenth Circuit Reverses Dismissal of Complaint Alleging False Claims Act Liability for Unnecessary Surgical Procedures

On July 9, 2018, in United States ex rel. Polukoff v. St. Mark’s Hosp., the Tenth Circuit Court of Appeals added to the debate over the role of the False Claims Act in policing medical necessity. ...more

Jones Day

Strategic Budgeting Can Result in Early Resolution of False Claims Act Cases

Jones Day on

The Situation: False Claims Act ("FCA") cases are high-risk matters, given their potential to result in "company-busting judgments." The Strategy: The high stakes require defendants and their counsel to treat the budget...more

Mintz - Health Care Viewpoints

Tenth Circuit Revives FCA Claim Based on Alleged Lack of Medical Necessity

The Tenth Circuit Court of Appeals has issued a significant decision, finding that a physician’s medical judgment about the medical necessity of heart procedures can be “false or fraudulent” under the federal False Claims Act...more

Cadwalader, Wickersham & Taft LLP

Untimely Physician Certifications for Medicare Home Care Claims—Arguably a Technicality—Vulnerable to False Claims Act...

On June 11, 2018, the United States Court of Appeals for the Sixth Circuit sustained a complaint against a home health care agency alleging that the agency had violated the False Claims Act (the “FCA”) by submitting numerous...more

Holland & Knight LLP

Federal Court Allows False Claims Act Case to Continue Against Medicare Advantage Insurer

Holland & Knight LLP on

In February of 2018, a United States District Court in the Central District of California dismissed only half of the claims in a qui tam case against United Health Group, Inc. (UHG), a Medicare Advantage plan provider. United...more

Sheppard Mullin Richter & Hampton LLP

Escobar’s Demanding Materiality Standard Nixes $350 Million Verdict Against Florida Nursing Facility

A Florida federal court threw out a $350 million jury verdict against a nursing facility, citing the Supreme Court’s landmark decision in Universal Health Services, Inc. v. United States ex rel. Escobar. The court explained...more

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