The Centers for Medicare and Medicaid Services (“CMS”), in a final rule published December 5, 2014, has elected not to proceed with a proposal to increase its whistleblower reward incentive from $1,000 to $10 million. Medicare Program; Requirements for the Medicare Incentive Reward Program and Provider Enrollment, 79 Fed. Reg. 72,500 (Dec. 5, 2014) (to be codified at 42 C.F.R. pt. 405) (effective Feb. 3, 2015). The proposal was inspired by the Internal Revenue Service’s success with its whistleblower program. However, the agency determined that increasing the incentives in the health care context could create problems for providers trying to deal with baseless allegations. The agency noted that the False Claims Act already provides a substantial financial incentive for whistleblowers who are willing to proceed with lawsuits, and creating a significant incentive for whistleblowers who simply report fraud to the agency could encourage whistleblowers to bring claims that are unwarranted and burdensome. It also expressed concern that a plan to limit eligibility to the first person to report a fraud would encourage a “shoot first, ask questions later” mentality.