With the continued proliferation of qui tam False Claims cases showing no signs of slowing down, not only must providers consider the amount of any monetary settlements, they must also consider whether the Office of Inspector General for the Department of Health & Human Services ("OIG") will require a corporate integrity agreement ("CIA").
A new presidential administration doesn't mean the long list of DOJ regulations impacting healthcare has gone to the wayside. Instead, federal agents continue to up their game when it comes to cracking down on fraud, Stark violations.
The Supreme Court decided Universal Health Services v. U.S. ex rel. Escobar on June 16, 2016 in which it ruled the implied false certification theory, previously recognized in several circuits, can form the basis for False Claims Act ("FCA") liability. However, the Supreme Court put limits on the application of the theory.
With the increase of Qui Tam lawsuits alleging violations of the federal False Claims Act ("FCA"), it is important to understand that FCA liability maybe predicated on whether the alleged wrongful act violated a condition of payment or a condition of participation.
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