Compliance

Interface Rehab will pay $2 million to resolve allegations that it violated the False Claims Act by causing the submission of claims to Medicare for rehabilitation therapy services that were not reasonable or necessary. According to the government, between 2006 and 2014, Interface knowingly submitted or caused the submission of false claims for medically unreasonable […]

Bluewater Toxicology LLC will pay more than $1.2 million to resolve civil allegations that it violated the False Claims Act in connection to its invoices for drug testing services. The government alleged that Bluewater submitted claims that mispresented the number of drug classes tested and submitted certain claims without sufficient documentation to support the treating […]

A panel of the U.S. Court of Appeals for the Fifth Circuit recently rejected an argument advanced by two subsidiaries of a nationwide health...

A divided panel of the Ninth Circuit recently reversed a district court decision that held that local coverage determinations (“LCDs”) are valid only when issued through a 60-day notice-and-comment rulemaking process. Agendia, Inc. v. Becerra, No. 19-56516 (9th Cir. July 16, 2021). The impact of the district court’s ruling—and a spirited dissent from the Ninth […]

The first Foreign Corrupt Practices Act case under President Joe Biden’s administration reinforces some well-known risks for companies subject to the FCPA — namely, increased U.S. and international enforcement and cooperation as well as the risks related to public contracting and tenders, the use of third-party agents, successor liability following merger and acquisition activity, and […]

In the fourth of a series of postings, Michael Volkov reviews a variety of recent FCA cases which demonstrate his point that companies should promptly prepare for an enforcement onslaught over the next few years. Akron General Health Systems agreed to pay $21.25 million to resolve allegations that it paid referring physicians substantially in excess […]

Ephraim Garcia, a former civilian employee of the U.S. Army’s Directorate of Public Works, has pleaded guilty to offering kickbacks to steer government contracts for work at Camp Arifjan, an Army base in Kuwait. Garcia admitted to conspiring with Gandhiraj Sankaralingam, the former general manager and co-owner of Kuwait-based Gulf Link Venture Co., to steer […]

Two Texas companies have agreed to pay a combined $15.3 million to resolve allegations of kickbacks and other misconduct resulting in the submission of false claims to federal health care programs. Alliance Family of Companies LLC, a national EEG testing company, allegedly paid kickbacks to referring physicians by providing them with free reports they could […]

On July 7, 2021, the Fifth Circuit affirmed a district court’s grant of the United States’ motion to dismiss—over the relator’s objection—two qui tams that challenged pharmaceutical patient support programs.  While the court’s decision is consistent with those of other courts of appeal that have confirmed DOJ’s broad authority to dismiss qui tams over relators’ objections, the […]

World Law Group hosted a webinar on Anti-Corruption Compliance and Enforcement Trends in the US and Globally on July 19th. Attorneys from Arnold & Porter provided an overview of the US Foreign Corrupt Practices Act (FCPA), global enforcement trends relating to the FCPA, the UK Bribery Act (UKBA), and other anti-corruption laws, and what authorities […]