The United States District Court for the Eastern District of Michigan recently dismissed a False Claims Act (“FCA”) lawsuit brought against the City of Detroit. The core issue in United States ex rel. Lynn v. City of Detroit revolved around Detroit’s annual certifications and assurances to comply with federal laws and regulations as a condition
Compliance
Significant Implications for FCA Defendants: Second Circuit Clarifies “Willfulness” in McKesson Decision
Posted in False Claims Act
In a pivotal ruling that may reshape the landscape of False Claims Act (“FCA”) litigation, the United States Court of Appeals for the Second Circuit adopted a nuanced interpretation of “willfulness” under the federal Anti-Kickback Statute (“AKS”).
Continue Reading Significant Implications for FCA Defendants: Second Circuit Clarifies “Willfulness” in McKesson DecisionOIG Issues Updated General Compliance Program Guidance: Overview of Key Elements & Changes
By Michael Shaheen, Roma Sharma & Michelle Chipetine on
Posted in False Claims Act
The Office of the Inspector General (OIG) of the U.S. Department of Health and Human Services (HHS) published the General Compliance Program Guidance (GCPG) on November 6, 2023. The GCPG provides updated descriptions of the seven elements of an effective compliance program that health care entities have long relied upon. The new guidance also includes…