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Fourth Circuit En Banc Vacates Application of Safeco to FCA Cases

USA - September 29 2022 The Fourth Circuit, evenly divided while sitting en banc, recently unwound a panel decision finding that Safeco’s “reckless disregard” standard…

Matt Bergs, Jaime L.M. Jones

HHS-OIG Flags Certain Extreme Outlier Telehealth Providers as Potentially Engaging in Fraudulent Billing During the Pandemic

USA - September 15 2022 HHS-OIG recently issued a report assessing Medicare program integrity risks arising from telehealth services furnished during the first year of the…

Jaime L.M. Jones, Francesca R. Ozinal

Provider Escapes, Contractor Remains in Qui Tam Alleging Noncompliance With Bad Debt Regs

USA - August 26 2022 Recently, the Seventh Circuit partially reversed a district court’s dismissal of a qui tam complaint alleging that debt collection agencies and their…

Jaime L.M. Jones, Francesca R. Ozinal

Fourth Circuit Underscores the Risk of Commission-Based Compensation Agreements with Independent Contractors

USA - August 2 2022 In a recent decision, the Fourth Circuit Court of Appeals for the second time in two years held that commission-based compensation arrangements with…

Ahsin Azim, Jaime L.M. Jones

Eighth Circuit Holds that AKS Violations Do Not “Taint” All Claims

USA - August 1 2022 The Eighth Circuit Court of Appeals recently issued a notable decision that offers defendants in FCA cases premised on violations of the…

Joseph R. LoCascio, Scott D. Stein