News & Analysis as of

False Claims Act (FCA) White Collar Crimes

Sheppard Mullin Richter & Hampton LLP

Update – Penn State to Pay Up for Cyber-Related FCA Case

On October 22, 2024, the Department of Justice (“DOJ”) announced that Pennsylvania State University (“Penn State”) has agreed to pay $1,250,000 to settle a False Claims Act (“FCA”) case brought against the University...more

Perkins Coie

Novel Decision Striking Down False Claims Act’s Qui Tam Statute Tees Up Further Litigation Over Whistleblower Lawsuits

Perkins Coie on

A recent Florida district court decision declared that the False Claims Act’s (FCA) qui tam provision violates the Constitution by vesting executive power in private whistleblowers (relators) that have not been appointed by...more

Bradley Arant Boult Cummings LLP

Federal Grant Recipients and Applicants Face New and Increased Obligations to Disclose Potential Wrongdoing

Mandatory disclosure obligations significantly changed for federal grant recipients, sub-recipients, and applicants on October 1, 2024. The amended federal regulation establishing these mandatory disclosures (2 C.F.R. §...more

Bradley Arant Boult Cummings LLP

Federal District Court in Florida Holds FCA’s Qui Tam Provisions Unconstitutional

Mandatory disclosure obligations significantly changed for federal grant recipients, sub-recipients, and applicants on October 1, 2024. The amended federal regulation establishing these mandatory disclosures (2 C.F.R. §...more

Kohn, Kohn & Colapinto LLP

Unitary Executive Theory Surfaces in Court: District Court Rules Qui Tam Provisions of the False Claims Act Unconstitutional

On September 30, 2024, the United States District Court for the Middle District of Florida ruled that filing claims on behalf of the government under qui tam provisions of the False Claims Act (FCA) is unconstitutional in...more

Vinson & Elkins LLP

Supreme Court Declines to Revisit Limitations on Anti-Kickback Statute: What This Means for Enforcement of Corruption, Kickbacks...

Vinson & Elkins LLP on

On October 7, 2024, the U.S. Supreme Court declined to hear a case concerning the “willfulness” element of the Anti-Kickback Statute (the “AKS”). This decision leaves intact a recent Second Circuit holding, which established...more

DLA Piper

Federal Judge Rules Whistleblower Provision of the False Claims Act is Unconstitutional

DLA Piper on

In an eye-opening decision, a judge in the Middle District of Florida held that the unique whistleblower, or “qui tam,” provision of the federal False Claims Act (FCA) violates the Appointments Clause of Article II of the...more

Parker Poe Adams & Bernstein LLP

Fourth Circuit Increases Defendants' Exposure in White Collar Cases, Interpreting 'Loss' as Either Actual or Intended Financial...

For years, it has been unsettled in the Fourth Circuit Court of Appeals whether a white-collar defendant may be held accountable for intended loss amounts during sentencing in fraud and other financial harm cases. Prosecutors...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Enters First Intervention in Cybersecurity Qui Tam

The U.S. government’s recent complaint in a relator-filed case under the False Claims Act (FCA): - Marks the first FCA suit in which the Department of Justice (DOJ) has intervened since launching its ongoing Civil...more

McCarter & English Blog: Government Contracts...

A New Frontier in Corporate Accountability: The DOJ’s Corporate Whistleblower Awards Pilot Program

On August 1, 2024, the US Department of Justice (DOJ) Criminal Division introduced its Corporate Whistleblower Awards Pilot Program (Program), which, like a modern-day Western posse, aims to bring justice to the wild frontier...more

Epstein Becker & Green

The Department of Justice’s COVID-19 Enforcement Task Force 2024 Report: A Continued Commitment to Combatting COVID-19-Related...

Since the pandemic, COVID-19-related fraud has been a consistent target of the Department of Justice....more

Jones Day

DOJ Announces Corporate Whistleblower Awards Pilot Program

Jones Day on

The Development: On August 1, 2024, the Department of Justice's ("DOJ") Criminal Division announced its Corporate Whistleblower Awards Pilot Program ("Pilot Program"), designed to reward whistleblowers who report information...more

Morrison & Foerster LLP

Corporate Whistleblower Awards Pilot Program

On August 1, 2024, Deputy Attorney General Lisa Monaco announced the launch of DOJ’s Corporate Whistleblower Awards Pilot Program (Pilot Program). The Pilot Program, previewed by Monaco in March 2024, provides another avenue...more

K&L Gates LLP

Private Equity Firms Should Prepare for Increased Scrutiny as DOJ Puts False Claims Violations Under the Microscope

K&L Gates LLP on

Private equity investment in health care has grown significantly over the past two decades, and the US government is starting to pay attention. Recent announcements by the US Department of Justice (DOJ) and proposals by...more

Oberheiden P.C.

A Guide to Qui Tam Lawsuits for Whistleblowers

Oberheiden P.C. on

One avenue for whistleblowers to take to report fraud against the government is to file a qui tam lawsuit under the federal False Claims Act. These lawsuits are complex because they have not two, but three parties to them –...more

K&L Gates LLP

The False Claims Act and Health Care: 2023 Recoveries and 2024 Outlook

K&L Gates LLP on

On 22 February 2024, the US Department of Justice (DOJ) published the statistics for federal civil fraud recoveries in Fiscal Year (FY) 2023. The DOJ announced that the “government and whistleblowers were party to 543...more

Oberheiden P.C.

A Handy Guide for Healthcare Whistleblowers

Oberheiden P.C. on

The healthcare industry relies heavily on whistleblowers to bring fraudulent conduct and other forms of waste and abuse to the attention of regulators, law enforcement, and the public in general. If you have found signs of...more

Bradley Arant Boult Cummings LLP

FCA Settlements with Companies on Government Cybersecurity Concerns Continue

On Monday, June 17, 2024, the Department of Justice (DOJ) announced settlements involving $11.3 million in payments for consulting companies failing to comply with cybersecurity requirements in federally funded contracts. The...more

Snell & Wilmer

Department of Justice Announces Groundbreaking Whistleblower Program in its Ongoing Effort to Incentivize Voluntary Self...

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Department of Justice (DOJ) Deputy Attorney General Lisa Monaco announced that the DOJ is adopting a whistleblower incentive program today at the American Bar Association’s 39th National Institute on White Collar Crime. In...more

Morgan Lewis - Health Law Scan

Mass. USAO Hints at Healthcare Fraud Enforcement Focus in Rare Disease Space at White Collar Crime Conference

The Boston Bar Association hosted its fifth annual White Collar Crime Conference on May 2, 2024, featuring prosecutors from the US Attorney’s Office for the District of Massachusetts (the Office) and the Office of the...more

Foley Hoag LLP - White Collar Law &...

Practitioners' Takeaways From the 2024 BBA White-Collar Crime Conference

On May 2, 2024, the Boston Bar Association (BBA) held its fifth annual White-Collar Crime Conference, featuring panel discussions with current and former prosecutors at the state and federal levels, defense counsel, and...more

Oberheiden P.C.

10 Tips for Filing a Qui Tam Lawsuit in 2024

Oberheiden P.C. on

The federal government is continuing to rely heavily on whistleblowers in 2024. While there are now several federal whistleblower programs, the qui tam provisions of the False Claims Act remain among the government’s most...more

Husch Blackwell LLP

Let’s Make a Deal with DOJ: The Impact of the DOJ’s New Whistleblower Reward Program on Corporate Compliance

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While Monty Hall (or for the current generation, Wayne Brady) was nowhere in sight, it was difficult not to think about the show “Let’s Make a Deal” while sitting in the audience at the American Bar Association’s 39th...more

Dentons

Ep. 12 - Working with Valuation Experts to Substantiate Fair Market Value Compensation

Dentons on

We often work with valuation experts to ensure compensation payments between healthcare organizations and physicians are fair market value and commercially reasonable for purposes of compliance with the Stark Law and the...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Pilot Program Promises Non-Prosecution Agreements to Individuals Reporting Fraud, Bribery and Other Corporate Crimes

On April 15, 2024, the Department of Justice’s (DOJ’s) Criminal Division unveiled a new Pilot Program on Voluntary Self-Disclosures for Individuals that offers non-prosecution agreements (NPAs) to individuals who voluntarily...more

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