This is the third in a series of client alerts addressing the likely role of the False Claims Act in the wake of the massive federal government response to the COVID-19 pandemic.

The healthcare industry is no stranger to False Claims Act (FCA) enforcement. In 2018, the Department of Justice (DOJ) recovered $2.5 billion in settlements and judgments for violations of the FCA by companies and individuals working in the healthcare industry, including large hospitals, drug and medical device manufacturers, pharmacies, hospice organizations, and doctors. And in 2019, healthcare recoveries amounted to more than 85% ($2.6 billion out of $3 billion) of total amounts paid under the FCA.