In a much-anticipated False Claims Act (FCA) ruling, the Eleventh Circuit has joined every other circuit in considering the issue and holding that qui tam relators under the FCA are not “officers of the United States” subject to the Constitution’s
Latest from Inside the False Claims Act
Medicare Advantage Fraud Enforcement in 2026: What Recent Settlements Reveal About the Limits of Data-Driven False Claims Act Cases
Over the last several months, there has been no shortage of commentary about the Department of Justice’s (DOJ) Fraud Oversight through Careful Use of Statistics (FOCUS) initiative and the rise of data-driven False Claims Act (FCA) investigations. DOJ has made
The Villages Health System Settles Medicare Advantage Risk-Adjustment Allegations for $541.5 Million
On August 26, the Department of Justice (DOJ) announced that The Villages Health System, LLC (TVH), a healthcare provider group located within The Villages retirement community in central Florida, agreed to a $541.5 million settlement to resolve False Claims Act
Deloitte DEI Settlement Highlights False Claims Act Risk at Both Federal and State Levels
The U.S. Department of Justice (DOJ) announced on August 25 that Deloitte has agreed to pay $21.5 million to resolve allegations that certain diversity, equity, and inclusion (DEI) practices discriminated against employees and applicants based on race or sex and
Medicaid Fraud Enforcement in 2026: High-Risk Areas for Home Care, Behavioral Health and Skilled Nursing Providers
As described in a previous blog post, the 2026 DOJ Health Care Fraud Takedown reflects an increased enforcement focus on Medicaid. Because Medicaid dollars are both federal and state in origin, a single set of allegations can expose a
What Happens in Vegas…Gets DOJ’s Attention: $95M Wound Care Fraud Indictment
On August 5, the U.S. Department of Justice (DOJ) announced that a federal grand jury in the District of Nevada returned a six-count indictment charging Stephen Dubin, M.D., of Henderson, Nevada, with conspiracy to commit healthcare fraud and five
DOJ’s $6.5 Billion National Health Care Fraud Takedown Signals a New Era of Data-Driven Enforcement
The Department of Justice (DOJ) recently announced the largest National Health Care Fraud Takedown in its history, charging 455 defendants—including 90 physicians and other licensed medical professionals—in schemes involving more than $6.5 billion in alleged false claims.
Smoke is Not Fire: Fourth Circuit Rejects Stark and AKS Theories Built on Ordinary Business Practices and Conclusory Allegations
It is not every day that an 83-page qui tam complaint alleging Stark Law and Anti-Kickback Statute (AKS) violations is dismissed at the pleading stage, particularly when filed by experienced relator’s counsel and accompanied by more than 30 pages of
Procurement Fraud Enforcement Trends Continue Into 2026
Legal Hurdles in Using FCA to Challenge DEI Programs
In a recent article for Law360, I examined the significant challenges the Department of Justice (DOJ) may face as it seeks to use the False Claims Act (FCA) to pursue allegedly unlawful diversity, equity, and inclusion (DEI) practices.