Home Compliance Seventh Circuit Holds That 2009 CMS Letter Triggered Public Disclosure Bar for... ComplianceExpert OpinionNews Seventh Circuit Holds That 2009 CMS Letter Triggered Public Disclosure Bar for Pre- and Post-Letter Conduct August 16, 2017 5 Share FacebookLinkedinTwitter You must be a Paid or Free Trial Member to Access this Content. Paid members, please login to view your news subscription(s). RELATED ARTICLESMORE FROM AUTHOR Compliance Relator Can’t Escape First-To-File Rule By Amending Complaint Compliance Second Circuit Defines “Willfulness” Standard Under Anti-Kickback Statute Compliance A Guide for Whistleblowers Under the False Claims Act