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Eleventh Circuit Rejects Appointments Clause Challenge to Qui Tam Mechanism
By Kristin Graham Koehler, Jaime L.M. Jones, Kwaku A. Akowuah, Joshua J. Fougere, Joseph R. LoCascio
In a landmark decision in Zafirov, the Eleventh Circuit yesterday rejected the argument that the FCA’s qui tam mechanism violates the Constitution’s Appointments Clause. Encouraged by concurring and dissenting opinions…
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DOJ Continues Medicare Advantage Enforcement Focus with $541.5 Million Settlement
By Jaime L.M. Jones, Matt Bergs, Lauren E. McBride
On August 26, 2026, the Department of Justice announced a $541.5 million settlement with a Florida-based provider group serving beneficiaries in the retirement community to resolve allegations that the group…
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DOJ Announces Second Settlement Resolving FCA Allegations Based on Employment Discrimination
By Kristin Graham Koehler, Jaime L.M. Jones, H. Boyd Greene IV, Kyle J. Fiet, Joseph R. LoCascio
Earlier this week, the Department of Justice (“DOJ”) announced a $21.5 million settlement agreement with five Deloitte entities to resolve allegations that they violated the FCA by engaging in conduct…
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Second Circuit Clarifies Scope of “Property” that an FCA “Claim” May Seek
By Jaime L.M. Jones, Kwaku A. Akowuah, Joseph R. LoCascio
Earlier this month, the Second Circuit issued a notable decision on a rare FCA topic—whether a request to the government seeks “property,” such that the request falls within the FCA’s…
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DOJ’s $5.15 Million FCA Settlement Reinforces Focus on Tariff and Customs Compliance
By Kristin Graham Koehler, Ted Murphy, Craig Francis Dukin, Aaron M. Applebaum, Jaime L.M. Jones, Lisa H. Miller, Michael D. Mann, Kenneth G. Coffin, Anna M. Schmitt
On August 5, 2026, DOJ announced a $5.15 million settlement with a Taiwanese light-emitting diode (“LED”) manufacturer and its Texas-based subsidiary to resolve allegations under the False Claims Act (“FCA”),…
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$14.1 Million FCA Settlement Underscores Medicare Advantage Coding Scrutiny
By Jaime L.M. Jones, Matt Bergs, Anna M. Schmitt
On August 3, 2026, DOJ announced a $14.1 million settlement with a management services organization (“MSO”) for primary care groups to resolve allegations that the organization violated the False Claims…
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New York Ethics Opinion Addresses Ethical Limits on Attorney Participation in Whistleblower Investigations
By Jaime L.M. Jones, Kenneth G. Coffin, Michael D. Mann
Lawyers representing False Claims Act whistleblowers need to be mindful of a practical question before a qui tam complaint is filed: how far may counsel go in helping a client…
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Laboratory, Owners, and Investors Settle COVID-19 Testing Fraud Allegations for $24 Million
By Jaime L.M. Jones, Michael D. Mann, Lauren E. McBride
On July 23, 2026, the Department of Justice announced that clinical lab Magnolia Diagnostics and its owners agreed to pay $19.2 million to resolve allegations that they violated the False…
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DOJ Releases FOCUS Questionnaire to Assist in Evaluating Qui Tams Filed by Data Miners
By Kristin Graham Koehler, Jaime L.M. Jones, Matt Bergs, Joseph R. LoCascio, Anna M. Schmitt
As we previously reported here, the Department of Justice has launched its Fraud Oversight through Careful Use of Statistics (“FOCUS”) initiative. The initiative gives data miners an opportunity to meet…
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June DOJ/SBA FCA Settlement Highlights Continued Focus on Contractor Compliance
By Kristin Graham Koehler, Jaime L.M. Jones, H. Boyd Greene IV, Kenneth G. Coffin, Dana Diaz, Anna M. Schmitt
On June 9, 2026, DOJ announced a settlement with Broadway Electric Inc. (“Broadway”); its subsidiary, Cornerstone Contracting Inc. (“Cornerstone”); and two of their individual executives, for $21.3 million to resolve…