On May 13, the U.S. Supreme Court unanimously affirmed a decision by the U.S. Court of Appeals for the 11th Circuit, holding that the False Claims Act’s (“FCA”) limitations period in 31 U.S.C.(b)(2) applies to “relator-initiated actions” in which
Zach Smith (US)
DOJ issues guidance on cooperation credit in FCA investigations
On May 7, the Department of Justice (“DOJ”) released an update to its previous 2017 guidance (“Updated Guidance”) outlining when the government will award cooperation credit to defendants in False Claims Act (“FCA”) investigations. Under the Updated Guidance, set forth at Justice Manual Section 4-4.112, defendants can earn cooperation credit in FCA cases in three primary ways.
OIG approves charitable cost-sharing subsidies to financially-qualified patients
In an Advisory Opinion posted on June 4, 2015, the Office of Inspector General for the Department of Health and Human Services advised that a proposed arrangement involving financial assistance to individuals with chronic diseases would not constitute grounds…
Texas Medical Board limits telemedicine
The Texas Medical Board recently voted to place strict limits on the use of telemedicine in the state. The Board’s decision runs counter to a growing trend toward loosening restrictions on telemedicine services.
Under existing Texas medical practice rules, a…