In Elkharwily v. Mayo Holding Co., No. 12-3062 (D. Minn. July 2, 2013), the court found that an anti-retaliation provision in a company’s compliance program did not create a contractual obligation. The case arose out of the dismissal of a hospitalist who allegedly had complained to supervisor and others about practices he said compromised patient safety and practices he claimed constituted fraudulent billing. The hospitalist sued on a variety of theories. Certain claims, including for violation of the anti-retaliation provision of the False Claims Act, 31 U.S.S. § 3730(h), were held to survive defendant’s motion to dismiss. However, the court dismissed plaintiff’s breach of contract claim, which was based on a provision in defendant’s Integrity and Compliance Program that “an employee ‘who honestly and in good faith reports suspected wrongdoing, will be protected from retaliation.’” The court held that the compliance policy was merely a general statement of policy and not a valid contractual offer, so it did not support a contractual claim for retaliatory discharge.