False Claims Act Exposure for Beneficiaries of the Public Health and Social Services Emergency Relief Fund: Mitigating Risks of Ambiguous Terms & Conditions

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The CARES Act allocated $100 billion to healthcare providers, to be distributed by HHS through the Public Health and Social Services Emergency Relief Fund. Many providers have received payments since mid-April, and many more will be receiving additional funding in coming weeks. But these funds are subject to extensive terms and conditions, and with those conditions comes exposure to potential liability under the False Claims Act. It is critical to pay attention to the strings attached to those funds, taking steps now to mitigate the risk of potentially costly FCA claims that could arise later.

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